EPA Superfund record of decision : Compass Industries (Avery Drive).

EPA/ROD/R06-87/900
1987
EPA Superfund
Record of Decision:
COMPASS INDUSTRIES (AVERY DRIVE)
EPA ID: OKD980620983
OU 01
TULSA, OK
09/29/1987
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
COMPASS INDUSTRIES LANDFILL
TULSA COUNTY, OKLAHOMA
SEPTEMBER 1987
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Compass Industries, Tulsa County, Oklahoma.
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for this site developed in
accordance with Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and the National Contingency Plan (40 CFR Part 300).
The State of Oklahoma has concurred on the selected remedy. (Letter attached)
STATEMENT OF BASIS
This decision is based upon the administrative record for the Compass Industries
Superfund Site [index attached]. The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The major components of the selected remedy include:
! Installation of a cover which isolates contaminated material from human contact and
reduces infiltration or precipitation through the landfill area. The capping and closure
procedures will be designed in accordance with the Resource Conservation and
Recovery Act (RCRA) to achieve a goal of 10-7 cm/sec premeability. If a synthetic liner
is determined to be technically feasible and cost effective in accordance with the
preliminary cost estimates developed in the Feasibility Study, that liner shall be no
thicker than 30-40 mil.
! Collection and on-site treatment of contaminated groundwater in the upper, perched
water bearing zone, if deemed necessary through compliance monitoring following
installation of the cover material.
! Installation of fences and signs along the perimeter of the cap.
DECLARATION
The selected remedy is protective of human health and the environment, attains Federal
and State requirements that are applicable or relevant and appropriate and is
cost-effective. Finally it is determined that this remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable.
Compass Industries Landfill
Record of Decision Concurrences
The Compass Industries Landfill Record of Decision has been reviewed and I
concur:
TABLE OF CONTENTS
PAGE
I. SITE LOCATION AND DESCRIPTION
Site History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Remedial Investigation Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Potential Impact of Site on Human
Health and the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
II. ENFORCEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
III. COMMUNITY RELATIONS HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
IV. ALTERNATIVES EVALUATION
Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Description of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Evaluation of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
V. PROPOSED REMEDY
Rationale . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Consistency with the National Contingency Plan
and Superfund Statutes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Operation and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Future Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
VI. APPENDICES
A. Tables 1-4
B. Community Relations Responsiveness Summary
C. Agency for Toxic Substances and Disease Registry (ATSDR)/Centers for Disease
Control (CDC) Evaluation
D. Administrative Record Index
E. State Concurrence Letter
EXECUTIVE SUMMARY
The Compass Industries site is an abandoned landfill located west of Tulsa, Oklahoma.
The site occupies an abandoned limestone quarry. From 1972 to 1976 the site was
permitted and operated as a solid and industrial waste landfill.
Geologic investigations verify that the site is underlain by two aquifers. The Hogshooter
Formation contains a shallow aquifer and the Layton Sandstone member of the Coffeyville
Formation forms a deeper aquifer. The Hogshooter Formation forms an unconfined,
low-yield perched aquifer. Between the upper and lower aquifers is a sequence of 32 to 50
feet of shales. The relatively low permeability of these shale units acts as a partial confining
bed that restricts the downward migration of groundwater. Therefore, most of the
groundwater contamination is confined to the Hogshooter Formation and the overlying
soils.
Summary of Remedial Alternatives Selection for
Compass Industries Landfill
Tulsa County, Oklahoma
July 1987
I. SITE LOCATION AND DESCRIPTION
The Compass Industries site is an abandoned landfill located in a former limestone
quarry west of Tulsa, Oklahoma (Figure 1). It is situated directly west of the Chandler
Park softball facility, which is owned and maintained by Tulsa County. Physically, the
site is situated on a bluff approximately one-quarter mile south and 200 feet above the
Arkansas River. The site's topography slopes downward to the west and north and
ranges in elevation from approximately 770 to 860 feet above mean sea level. The
majority of runoff flows through water gaps in the ridge between the landfilled area and
the river or to ponds on the landfill. The clayey topsoil that is present is derived from
cover material utilized by the landfill operation. The natural soils in the area are
composed mainly of limestone residuum and similar constituents. Pioneer plant
species and grasses cover most of the site.
Site History
The Compass Industries site is located in a former limestone quarry which operated
from the 1930's through the 1950's. The site was permitted by the Oklahoma State
Department of Health and operated as a landfill from 1972 to 1976. There is evidence
that dumping occurred as early as 1964. As one of the major landfills in the Tulsa area
during those years, it accepted both municipal and industrial wastes. Unlike most
landfills in current operation, the operators of Compass Industries landfill apparently
kept few records concerning which wastes were disposed in the landfill. In addition, site
data indicates that disposal of the waste was done in an irregular manner, making it
difficult to ascertain where the wastes are located.
During the 1970's, several fires were reported at the landfill. The most recent fire
burned out in late 1984. It had burned underground for several years, breaking through
the topsoil cover on occasion. During this same time period, citizen complaints of
odors prompted air monitoring in the vicinity of the landfill. The results obtained from
this monitoring revealed the presence of some organics, but at levels that were
considered non-hazardous. Currently there are no known underground fires at the site;
however, there exits a potential for future fires.
The Compass Industries site was listed on the National Priorities List (NPL) in
September 1984, and funding for the remedial investigation and feasibility study was
provided by the U. S. Environmental Protection Agency (EPA).
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Geology
The Compass Industries site occupies an abandoned limestone quarry on a hilltop about
200 feet above the Arkansas River, and 1/4 mile south of the site on the north. Surface
water from precipitation runoff, springs, and seeps flows into the Arkansas River through a
simple network of small streams.
The Hogshooter Formation and the Coffeyville Formation outcrop in and around the site
(Figure 2), and comprise part of a sequence of shales, sandstones, and limestones
formed in shallow marine and deltaic environments in late Pennsylvanian time.
The Hogshooter Formation forms an unconfined, low-yield perched aquifer that is exposed
at the surface on all sides of the site. This aquifer is recharged directly from local
precipitation infiltration and is discharged through seeps and springs into surface waters
near and within the site.
A thick sandstone zone, the Layton Sandstone member of the Coffeyville Formation, forms
a second, somewhat deeper aquifer. It too recharges from precipitation and discharges
through seeps to surface water. No use of water from either of these aquifers is known.
Water table contour maps of each aquifer indicate that groundwater flows to the
west-northwest at the site.
The volume of the waste was determined to be approximately 620,000 cubic yards. The
average groundwater flow rate of both aquifers is 720 gallons per day or an estimated
263,000 gallons of water per year.
Remedial Investigation Results
During the RI of the Compass Industries site, samples were collected from soil, water, and
air to determine if significant pollutant concentrations are present. Routes of off-site
migration include surface runoff, groundwater (by way of recharge to seeps and surface
runoff), transported sediments, and air.
Analytical results of the samples collected from the site indicate a large number of organic
and inorganic priority pollutants were detected. They include a total of 12 inorganic priority
pollutants and at least 33 organic priority pollutants, the most common priority pollutants
being base-neutral compounds. The concentrations were greatest in samples of waste
collected from the surface and in test trenches.
Groundwater samples were collected from 19 monitoring wells during the RI. These include
18 samples collected from 14 shallow wells completed in the perched water table aquifer,
and eight samples collected from five deep wells completed in the Layton Sandstone.
5
Surface water runoff and sediment samples from drainageways were collected around the
perimeter of the landfill to determine if contaminated runoff and sediments were leaving the
site. Sampling sites for surface water runoff were selected following several on-site
inspections during rainfall events. The general direction of surface runoff is to the north and
northwest. Sites for sediment sampling were located using aerial photographs,
topographic maps, and on-site field surveys. Seven sediment samples from seven
locations were collected, generally in the same areas where runoff samples were
collected.
Ten seep samples were collected to determine if contaminants were being leached out of
the landfill wastes and transported. Seepage occurs along the perimeter of the landfill near
the contact between the Hogshooter Formation and Coffeyville Formation. Sampling sites
were located following a period of wet weather by observing potential seep areas
identified during the preceding winter. Freezing conditions during the winter permitted the
identification of seeps as ice was formed at the point of discharge from the bluffs.
Surficial soil samples were collected randomly around the perimeter and within the interior
of the site to determine if surficial soils were contaminated. Eleven soil samples were
collected at the 11 locations. One sample was collected near the site entrance as a
background sample for comparing constituent concentrations.
In order to determine the extent, characteristics, and distribution of the waste at the site,
samples were also collected from the bottom of 17 backhoe trenches.
Air samples were collected by the EPA Technical Assistance Team (TAT) during trench
excavation and waste sampling. These samples were collected immediately upwind,
downwind, and within the test pit. In addition, air monitoring using an organic vapor
analyzer (OVA) was performed at each trench during excavation.
Conclusions
The hydrogeologic and topographic setting of the Compass Industries site appears to
minimize the migration of contaminated groundwater both laterally and vertically. The site
is located on a bluff a short distance above the Arkansas River. Both the shallow and deep
aquifers (the Hogshooter Formation and Layton Sandstone member of the Coffeyville
Formation, respectively) outcrop around the entire perimeter of the site. The deep aquifer
is separated from the shallow aquifer by 35 to 50 feet of shale units. The relatively low
permeability of the shale acts as a partial confining bed that appears to restrict most of the
downward migration of contamination to the deep aquifer. Therefore, it appears that most
of the contaminated groundwater at the site is contained within the Hogshooter Formation
and overlying soils.
6
An evaluation of all sample results presented in the Remedial Investigation Report for the
Compass Industries site has resulted in the following interpretations on the extent and
concentration of hazardous wastes at the site.
1. Migration of contaminants in the groundwater is currently being mitigated by attenuating
mechanisms since much greater concentrations were measured in solid samples.
Possible attenuating mechanisms include compounds with relatively low solubility and
miscibility and high soil adsorption capacities.
2. Table 1 provides a list of the three highest concentrations of inorganic and organic
priority pollutant compound concentrations for samples of groundwater and waste. This
table shows that greater contaminant concentrations are present in the wastes than in
groundwater and that the deep groundwater is less contaminated than the shallow
groundwater. The highest concentrations of organic compounds for aqueous samples
were detected in the sample from USEPA/TAT well number one. This sample is
probably of an isolated zone of disposed liquid wastes.
3. Off-site contaminant migration is currently limited to surface runoff and seeps (which
are fed by groundwater). Currently this does not present a significant health threat.
4. Samples of groundwater from monitoring wells on the site is highly contaminated. This
indicates a degradation of groundwater quality die to waste disposal in both the
perched and deep aquifers. The perched aquifer is much more severely contaminated
than the deep aquifer.
5. Where wastes were sampled at the ground surface many samples contained
significant concentrations of both inorganic and organic priority pollutants. The surface
waste samples were similar in composition to wastes sampled from trenches.
6. The site's impact on air quality appears to be minimal at this time and it is only during
intrusive activities, such as trenching or during fires, that elevated levels of air
contaminants may present a health hazard.
7. The volume of the waste was determined to be approximately 620,000 cubic yards.
The average groundwater flow rate of both aquifers is 720 gallons per day.
Groundwater remediation will require treatment of an estimated 263,000 gallons of
water per year.
7
Potential Impact of Site on Human Health and the Environment
The three major pathways of possible off-site contaminant migration are surface water,
groundwater, and air. The possibility also exits for direct contact at the site with
contaminated source materials, such as sludge, soil, or sediments.
Surface water runoff and seeps that discharge along the perimeter of the site are the most
significant pathways of contaminant migration off-site. Exposure to surface water can be
by direct contact or by ingestion. The transfer of contaminants to off-site surface water is
another possible exposure pathway.
The majority of the contamination in the groundwater is confined to the upper aquifer.
Relatively impermeable shales between the upper and lower aquifers serve to reduce the
flow of contaminants to the lower aquifer. Significant concentrations of organic and
inorganic contaminants were detected in the shallow aquifer. A detailed analysis of the
contaminants detected is contained in the RI report.
The site contains a significant concentration of relatively low hazard gases, and exhibits
only trace quantities of toxic volatile organic vapors. A minimal respiratory hazard is posed
by the site, although a potential hazard may exist in the event of a subsurface disturbance
or fire. Exposure due to air emissions can be by inhalation or indirect contact. The source
material poses an exposure risk due to direct contact or by inhalation and ingestion of
airborne dust.
II. ENFORCEMENT
Approximately 20 Potentially Responsible Parties (PRPs) have been identified, and may
be given special notice to conduct the Remedial Design and Action. To date, there has
been no PRP involvement at the site.
III. COMMUNITY RELATIONS HISTORY
Several fires were reported in the landfill during the 1970's. The most recent fire burned for
several years before it apparently burned out in 1984. Air monitoring was conducted at the
site in response to citizen complaints of strong odors coming from the landfill. The results
obtained from the air monitoring showed the presence of organics, but at non-hazardous
levels. Investigations conducted by the Environmental Protection Agency (EPA) led to the
sites inclusion on the National Priorities List in September 1984.
On July 25, 1984, the U.S. Environmental Protection Agency (EPA) issued a news release
announcing that funds had been awarded to the Oklahoma State Department of Health
(OSDH). That money was used to conduct studies at the Compass Industries site.
8
The OSDH held a public meeting at the Berryhill High School on August 20, 1984, to
explain the project, answer questions, and take comments.
The completion of the studies was announced to the public via news releases issued by
the OSDH on July 16, 1987, and the EPA on July 22, 1987. The scheduling of the August
18, 1987, public meeting to discuss the proposed remedy for the site was also announced.
An EPA prepared fact sheet which described alternative cleanup plans along with the EPA
preferred alternative was sent to the interested and affected public on July 22, 1987. The
fact sheet gave a brief site history, described the process and alternatives and gave
details about the public comment period and public meeting.
Because of the increase in public interest the public meeting on August 18 was changed from
the original public library location to the Berryhill School auditorium so that enough seating
was assured. The change of location was announced in an EPA news release issued August
7, 1987.
Approximately 65 people attended the August 18, 1987, public meeting.
Community concerns centered around costs of the alternative remedies, efficiency and
public health.
Further details concerning Community relations are contained in Appendix C.
IV. ALTERNATIVES EVALUATION
Evaluation Criteria
Section 121(b),(1)(A-G) of the Superfund Amendments and Reauthorization Act contains
the nine factors which EPA must consider in selecting a remedy for a Superfund site.
These are summarized below:
1. Consistency with Other Environmental Laws
In determining appropriate remedial actions at Superfund sites, consideration
must be given to the requirements of other Federal and State environmental
laws, in addition to CERCLA as amended by SARA. Primary consideration is
given to attaining applicable or relevant and appropriate Federal and State
public health and environmental regulations and standards. Not all Federal and
State environmental laws and regulations are applicable to each Superfund
response action. The compliance of each remedial alternative with all applicable
and relevant environmental laws is shown in Table 2.
2. Reduction of Toxicity, Mobility or Volume
The degree to which alternatives employ treatment that reduces toxicity,
mobility, or volume must also be assessed. Relevant factors are:
9
! The treatment processes the remedies employ and materials they will treat;
! The amount of hazardous materials that will be destroyed or treated;
! the degree of expected reduction in toxicity, mobility, or volume;
! The degree to which the treatment is irreversible;
! The residuals that will remain following treatment, considering the
persistence, toxicity, mobility, and propensity for bioaccumulation of such
hazardous substances and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of alternatives must be assessed considering
appropriate factors among the following:
! Magnitude of reduction of existing risks;
! Short-term risks that might be posed to the community, workers, or the
environment during implementation of an alternative including potential
threats to human health and the environment associated with excavation,
transportation, and redisposal or containment;
! Time until full protection is achieved.
4. Long-term Effectiveness and Permanence
Alternatives are assessed for the long-term effectiveness and permanence they
afford along with the degree of certainty that the remedy will prove successful.
Factors considered are:
! Magnitude of residual risks in terms of amounts and concentrations of waste
remaining following implementation of a remedial action, considering the
persistence, toxicity, mobility, and propensity for bioaccumulation of such
hazardous substances and their constituents;
! Type and degree of long-term management required, including monitoring
and operation and maintenance;
! Potential for exposure of human and environmental receptors to remaining
waste considering the potential threat to human health and the environment
associated with excavation, transportation, redisposal, or containment;
10
! Long-term reliability of the engineering and institutional controls, including
uncertainties associated with land disposal of untreated wastes and
residuals;
! Potential need for replacement of the remedy.
5. Implementability
The ease or difficulty of implementing the alternatives are assessed by
considering the following types of factors:
! Degree of difficulty associated with constructing the technology;
! Expected operational reliability of the technologies;
! Need to coordinate with and obtain necessary approvals and permits (e.g.,
NPDES, Dredge and Fill Permits for off-site actions) from other offices and
agencies;
! Availability of necessary equipment and specialists;
! Available capacity and location of needed treatment, storage, and disposal
services.
6. Cost
The types of costs that should be assessed include the following:
! Capital cost;
! Operation and maintenance costs;
! Net present value of capital and O & M costs;
! Potential future remedial action costs.
7. Community Acceptance
This assessment examines:
! Components of the alternatives that the community supports;
! Features of the alternatives about which the community has reservations;
! Elements of the alternatives which the community strongly opposes.
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8. State Acceptance
Evaluation factors include assessments of:
! Components of the alternatives the State supports;
! Features of the alternatives about which the State has reservations;
! Elements of the alternatives under consideration that the State strongly
opposes.
9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against individual evaluation
criteria, the alternatives are assessed from the standpoint of whether they
provide adequate protection of human health and the environment considering
the multiple criteria.
EPA is also directed by SARA to give preference to remedial actions that utilize
treatment to remove contaminants from the environment. Offsite transport and
disposal without treatment is the least preferred option where practicable
treatment technologies are available.
Description of Alternatives
In conformance with the National Contingency Plan, an initial set of remedial approaches
were screened to determine whether they might be appropriate for this site. (See the
Feasibility Study for details of this evaluation). From these possible remedies, six
alternatives were chosen for more detailed evaluation and comparison with the remedy
selection criteria outlined above. Each is summarized below:
ALTERNATIVE 1, NO-ACTION - This remedy, consists primarily of restricting public
access to the contaminated areas and monitoring the site. The area will be fenced
and warning signs will be installed. Site monitoring will involve periodic air and
groundwater sampling and analysis. The estimated cost to implement the no action
alternative is $672,000.
Four of the remedial action alternatives include a cap which meets RCRA specifications.
The RCRA specification cap will isolate the contaminated source material from potential
public and wildlife contact and will significantly reduce the infiltration of precipitation
through the landfiIled area. Surface water diversion technologies will also be implemented
to reduce flow over the surface and to reduce the potential for infiltration. The cap will be
graded to encourage site run-off and simultaneously prevent erosion of the soil and
vegetative cover. The cap design includes gas collection and atmospheric venting, which
will be monitored up-gradient and down-gradient of the site in both the
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shallow and deep aquifers. Groundwater that emerges from the downgradient hillside to
become surface water will also be monitored. Fences and signs will be placed along the
perimeter of the site to protect the cap from disturbances.
ALTERNATIVE 2, CAP AND ON-SITE GROUNDWATER TREATMENT - This
alternative, is comprised of site grading, cap placement, diversion of surface water,
groundwater collection and treatment, and air emissions monitoring. The grading,
cap design, gas venting, and surface water diversion technologies were presented
in the previous paragraph. Groundwater will be collected prior to its emergence
from the down-gradient hillside. The contaminated groundwater will be collected,
combined, and treated to State and Federal standards prior to discharge to the
Arkansas River. A filtration unit will be specified such that effluent solids levels meet
National Pollution Discharge Elimination System (NPDES) requirements. The
precipitated metals and other solids from the separation unit will be dewatered. For
purposes of cost estimation it is anticipated that the solids will be processed in a
mechanical filter unit and disposed as a hazardous solid waste material in a
permitted, off-site landfill if the material meets the criteria for land disposal. The
estimated cost of the cap and on-site groundwater treatment alternative is $12
million.
ALTERNATIVE 3, CAP AND OFF-SITE GROUNDWATER TREATMENT
ALTERNATIVE - This remedy is similar to Alternative 2 except that the groundwater
will be collected and transported to an off-site treatment facility. It is anticipated that
the groundwater will be placed into a 10,000-gallon holding tank. Groundwater will
be routinely transported for off-site treatment and disposal. The estimated cost of
the cap and off-site groundwater treatment alternative is $13 million.
ALTERNATIVE 4, FULL ON-SITE THERMAL DESTRUCTION ALTERNATIVE -
Involves removing all landfilled material and destroying it in an on-site thermal
destruction unit for destruction or removal of 99.99 percent of the organics.
Materials handling will include hauling hazardous waste materials, contaminated
soils and sediments, and the non-hazardous landfill material to the on-site thermal
treatment unit. Upon thermal destruction, the released volatile gases will be
collected and burned at a higher temperature and the stack gases will be scrubbed
and treated prior to atmospheric release. The residual ash will be tested, solidified
if necessary, and disposed of in an appropriate manner dependent upon
performance of the toxicity characteristic leaching procedure (TCLP) and other
relevant tests. The groundwater will be collected and treated similar to Alternative 2.
Performance specifications for treatment would be developed during remedial
design from information obtained during RI and would be the basis for the level of
thermal destruction. The performance specifications would address pretreatment
requirements, materials handling, testing, and disposal options. The estimated cost
of the full on-site incineration alternative is $339 million.
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ALTERNATIVE 5, PARTIAL ON-SITE THERMAL DESTRUCTION AND CAP -
Consists of excavating and thermally destroying the source areas of contaminated
material, capping the entire site, installing barriers, and collecting and treating the
contaminated groundwater. Residual ash will be solidified if necessary, and
disposed of in an on-site landfill which meets RCRA specifications or in an
appropriate manner following performance of the TCLP and other relevant tests.
The estimated cost of the partial on-site thermal destruction alternative is $17
million.
ALTERNATIVE 6, PARTIAL OFF-SITE THERMAL DESTRUCTION AND CAP -
This alternative is similar to Alternative 5 except treatment of contaminated wastes
and groundwater will be performed off-site on a service basis. The hazardous
material will be removed and transported to the off-site thermal treatment unit,
sized, and destroyed. Residual ash will be solidified, if necessary, and disposed of
in an off-site landfill which meets RCRA specification or in an appropriate manner
following performance of the TCLP and other relevant tests. The estimated cost of
the partial off-site thermal destruction alternative is $45 million.
Evaluation of Alternatives
The degree that the six remedial alternatives meet the nine selection criteria is contained
in Table 3. The following values were assigned to compare remedial selection criteria:
++ Alternative would greatly exceed a selection criterion when compared to other
alternatives.
+ Alternative would exceed a criterion in comparison to other alternatives.
0 Alternative can be designed to meet the selection criterion.
- Special efforts will be necessary in the design of the remedy to meet the selection
criterion.
-- In comparison to other remedies, these alternatives would present most difficulty in
achieving a selection criterion.
The rationale for the ratings assigned in this table is as follows:
1. COMPLIES WITH ARARs (i.e., meets or exceeds applicable or relevant and
appropriate Federal and State requirements)
Incineration was rated the highest for this criterion (++) because in addition to
exceeding all environmental rules, this alternative most effectively meets the preference
in SARA for destruction of contaminants. All other alternatives, except for the no action
alternative, received a rating of “+” because they all can be designed
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to exceed applicable standards. The no action remedy was rated”--“ because it does
not meet the intent of the RCRA and Superfund requirements for remediation of a
hazardous waste site. The National Contingency Plan provisions to respond to a threat
of release are also violated by this remedy.
2. REDUCES MOB., TOX., VOL. (i.e., Reduces the Mobility, Toxicity, or Volume of
Waste)
a. No Action was rated "--" because it does nothing to reduce any of these
parameters.
b. Cap and On-site Groundwater Treatment and Cap and Off-site Groundwater
Treatment (Alternatives 2 and 3) - Both of these alternatives were judged to
effectively reduce the mobility of contaminants. The groundwater treatment serves
to reduce the volume and toxicity of wastes on site to some degree and were
therefore rated "0".
c. Full On-site Thermal Destruction was rated "++" for each parameter because this
process would destroy the organic compounds in the waste.
d. Partial On-site Thermal Destruction, Cap, and Groundwater Treatment and Partial
Off-site Thermal Destruction, Cap, and Groundwater Treatment (Alternatives 5 and
6) - Because these two remedies would reduce the mobility of wastes only slightly
better than Alternatives 2 and 3, they were assessed to be essentially equivalent
and were rated "+". The partial destruction of wastes does result in reductions in
toxicity (meriting a single +) and a small reduction in volume (a rating of 0) when
compared to the simple cap and groundwater treatment remedies.
3. SHORT TERM EFFECTIVENESS
The simple capping remedies (alternatives 2 and 3) were judged capable of being
designed to present essentially no risks to workers or residents. The on-site thermal
treatment options were assigned a single "-" because these risks can be prevented but
would require attention in the design. The added risks of transporting untreated waste
long distances resulted in off-site thermal treatment receiving a “--" rating. Doing
nothing leaves contaminated seeps and waste exposed to the public, thus no action
rated
4. LONG TERM EFFECTIVENESS
All alternatives, except no action, will successfully reduce long term risks to human
health and the environment. Because of the added assurance from the destruction of
the organic waste, the full incineration was rated "++".
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5. IMPLEMENTABILITY
Onsite incineration remedies (alternatives 4 and 5) will require relatively more attention
during design than other remedies to ensure implementability and were therefore rated
lower ("-") than the other alternatives.
6. COST
Estimated costs for each alternative are summarized in Table 4. Included in this table
are total capital and implementation costs, annual operation and maintenance costs,
total present worth, and replacement costs. Replacement costs were included to
evaluate the cost of remedial action if the alternative were to fail. A replacement cost of
$5 million was assessed for the cap and on-site groundwater treatment alternative and
the cap and off-site groundwater treatment alternative. This replacement cost is an
estimate of replacement of the cap.
The no action alternative had the lowest present worth and operation and maintenance
costs. The cap and on-site groundwater treatment and the cap and off-site groundwater
treatment alternatives were the next least expensive, with costs of $12 million to $13
million.
Most of the added costs for the remedy involving off-site groundwater treatment are
due to added transportation expenses. The partial on-site and partial off-site thermal
treatment remedies have a present worth of $17 million and $45 million respectively.
The increased cost of the partial off-site thermal destruction, cap, and groundwater
treatment alternatives is due to transportation expenses and the higher prices vendors
charge at permitted off-site thermal treatment facilities. The full on-site thermal
destruction and groundwater treatment alternative has an estimated present worth of
$339 million. This alternatives excessive cost over the partial thermal treatment
remedies is due to the increased volume of waste to be treated. Only 2 percent of the
waste will be treated with the partial thermal treatment remedies.
7. COMMUNITY ACCEPTANCE
At the public meeting on August 18, 1987, the public had several comments and
concerns pertaining to all of the remedies. Questions ranged from the damage the
remedies will cause to the environment to the time required for cleanup of the site. The
no action alternative was left blank because it was not discussed by the public. The
remedies involving a cap and groundwater treatment were rated "+" because the public
was in favor of this action over thermal treatment of the waste. A rating of "-" was given
to the alternatives involving thermal destruction because of the public concern that the
thermal treatment unit would create hazardous emissions and increase the potential for
exposure.
16
8. STATE ACCEPTANCE
A rating of "0" was given to the cap and on-site groundwater treatment remedy as
proposed in the Feasibility Study. The State (i.e., the Oklahoma State Department of
Health) has concurred with the capping portion of this remedy. The final decision for
this site defers treatment of groundwater. A rating of "-" was given to all other
alternatives because the State did not support any of the other proposed remedies.
9. Overall Protection of Human Health and the Environment
Full on-site thermal destruction received the highest rate of “++” because it results in
elimination of the organic contaminants. The thermal treatment unit would be designed
to meet RCRA standards. The possibility exists that noxious odors will be given off
during the treatment process, but a contingency plan will be developed to address this
problem. Destruction of 99.99% of the organic contamination will reduce the potential
for human exposure.
The remaining alternatives, except for the no action alternative, were rated "+". This
rating is due to the health threat posed by untreated waste remaining on-site. The no
action alternative received a rating of "--" for the same reason. This remedy provides
no reduction in exposure pathways.
V. PROPOSED REMEDY: RCRA CAP
Rationale
Considering the current and potential site hazards, and also taking into account the unique
hydrology of the area, the recommended remedy is a RCRA cap. This alternative consists
of site grading, cap placement, diversion of surface water, and air emissions monitoring.
The site cap will be required to meet RCRA specifications. Groundwater will be treated at
a later date if found to be necessary. This alternative will also require installation of security
fences and signs to restrict access to the site.
The site will be monitored for a period of at least 30 years (post-closure time period
stipulated under RCRA) to ensure that no significant contaminant concentrations migrate
from the site. If however, future migration does occur appropriate remedial actions will be
taken.
This alternative is protective and cost-effective, attains applicable or relevant and
appropriate Federal and State standards, and utilizes
17
permanent solutions and treatment technologies to the maximum extent practicable. The
reasons for elimination of the other remedies are as follows:
Alternative No. 1; No-action; this alternative is not protective of public health and the
environment. It does not meet the intent of RCRA or SARA.
Alternative No. 3; Cap and off-site groundwater treatment; this alternative is the same as
alternative 2 except that it entails off-site groundwater treatment. This
remedy meets the requirements listed in RCRA, however it is relatively
more costly. The potential for human exposure would be increased due
to off-site transport of contaminants.
Alternative No. 4; Full on-site thermal destruction; complies with RCRA regulations and
also meets many of the preferences listed in SARA. However, this
remedy is not cost-effective ($339 million vs. $12 million).
Alternative 2 provides a safe solution to the hazardous waste problem
which allows that the waste be left on-site. It also takes advantage of
the site's unique hydrology and a RCRA cap to halt migration and
further contamination of the groundwater. For this reason, it can be
assumed that alternative 2 is protective to human health and the
environment.
Alternative No. 5; Partial on-site thermal destruction and cap; this alternative is also not
cost effective ($17 million vs $12 million). Under this proposal only one
percent or so of wastes would be destroyed yielding negligible
environmental benefits. As just stated, the increase in cost does not
justify the negligable increase in protection to human health and the
environment.
Alternative No. 6; Partial off-site thermal destruction and cap; this alternative meets the
requirements of RCRA and SARA. The potential for human exposure
would be increased due to off-site transportation. The minor increase in
protection to human health and the environment does not justify an
increased cost of $45 million.
Consistency with the National Contingency Plan (NCP) and the Provisions of the
Superfund Amendments and Reauthorization Act of 1986 (SARA)
The proposed remedy provides adequate protection of public health, welfare, and the
environment. This alternative is also consistent with the National Contingency Plan (NCP),
in 40 CFR 300.68(h)(2)(iv) and (vi) (Federal Register, 1985) which requires:
18
(iv) An assessment of each alternative in terms of the extent to which it is expected to
effectively mitigate and minimize threats to and provide adequate protection of public
health, welfare and the environment.
(vi) An analysis of any adverse environmental impacts, methods for mitigating these
impacts, and costs of mitigation.
Additionally, the long-term effectiveness factors cited in SARA Section §121(b)(1) were
addressed. These include:
A) The long-term uncertainties associated with land disposal;
B) The goals, objectives, and requirements of the Solid Waste Disposal Act;
C) The persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents.
D) Short- and long-term potential for adverse health effects from human exposure;
E) Long-term maintenance cost;
F) The potential for future remedial action costs if the remedial action in question were to
fail; and
G) The potential threat to human health and the environment associated with excavation,
transportation, and redisposal, or containment.
Operation and Maintenance (O&M)
Site operation and maintenance will include a groundwater and air monitoring and analysis
program, inspection of the surface vegetatIon, and the periodic repair of the perimeter
fence. Cap maintenance will entail the inspection of the cap and the maintaining and
replacing of the passive gas filters associated with the gas collection and venting system.
The State of Oklahoma will have the responsibility for O&M for a period of a least 30 years
after completion of the remedial action.
Future Actions
No future remedial actions are anticipated. The selected remedial action is considered
permanent. If, however, significant unforeseen off-site contamination occurs as a result of
the site, appropriate remedial measures will be taken. As stated under the O&M section,
the site will be monitored for a least 30 years to ensure the reliability of the implemented
remedial action.
SARA also states that if an alternative results in any hazardous substances, pollutants, or
contaminants remaining onsite, the remedy will be reviewed at least every five years to
assure that human health and the environment are being protected.
19
Remedial Action Schedule
Approve Remedial Action (sign ROD) September 1987
Complete Enforcement Negotiations January 1988
Obligate Funds to Begin Remedial Design January 1988
(assuming the PRPs do not take over)
Complete Design March 1989
Obligate Funds to Start Remedial Action March 1989
Complete Remediation September 1990
APPENDIX A
Table 1
COMPOUNDS HAVING HIGHEST CONCENTRATIONS IN
SAMPLES OF GROUNDWATER
Shallow Well
(ug/L)
Deep Well
(ug/L)
Inorganic Compounds Inorganic Compounds
zinc* 7497 barium 1450
lead* 3397 zinc* 1128
copper* 3162 chromium* 353
Organic Compounds Organic Compounds
2-methynaphthalene 98000 bis(2-ethylhexyl)
phenenthrene* 62000 phthalate* 30
bis(2-ethylhexyl)*
phthalate 46000
toluene*
di-n-butyl
phthalate*
6
0.8
COMPOUNDS HAVING HIGHEST CONCENTRATIONS
IN SAMPLES OF WASTE
Trenches
(mg/kg)
Surface Waste
(mg/kg)
Inorganic Compounds Inorganic Compounds
zinc* 2132 copper* 19930
chromium* 1639 zinc* 5450
lead* 1555 lead* 2790
Organic Compounds Organic Compounds
2 methylnaphthalene 5300 benzo (b)
phenenthrene* 250 fluoranthene* 1600
xylenes 190 benzo (a)
anthracene* 1100
pyrene* 710
* Priority pollutants
NOTE: Units equivalent to parts per million.
Does not include methylene chloride, a suspected lab
contaminant. Tentatively identified compounds (e.g.,
hydrocarbons) not included.
TABLE 2
TABLE OF REMEDIAL ALTERNATIVES COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL LAWS AND REGULATIONS
LAW OR REGULATION ANALYSIS
NO
ACTION
CAP AND
ON-SITE
GROUNDWATER
TREATMENT
CAP AND
OFF-SITE
GROUNDWATER
TREATMENT
FULL
ON-SITE
THERMAL
DESTRUCTION
PARTIAL
ON-SITE
THERMAL
DESTRUCTION
AND CAP
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
AND CAP
Federal
Resource Conservation
and Recovery Act
(RCRA)
Violations
likely
X
Compliance
demonstrated
or feasible
X X X X X
DOT Hazardous
Material Transport
Rules
Not
Applicable
X X X X
Compliance
demonstrated
or feasible
X X
Clean Air Act (CAA)
and National
Ambient Air Quality
Standards (NAAQS)
Not Applicable
Compliance
demonstrated
or feasible
X X X
X X X
Toxic Substances
Control Act (TSCA)
Not
Applicable
X X X X X X
National Pollutant
Discharge
Elimination System
(NPDES)
Requirements
Not
Applicable
Compliance
demonstrated
or feasible
X
X
X X X X
TABLE 2 (continued)
TABLE OF REMEDIAL ALTERNATIVES COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL LAWS AND REGULATIONS
LAW OR REGULATION ANALYSIS
NO
ACTION
CAP AND
ON-SITE
GROUNDWATER
TREATMENT
CAP AND
OFF-SITE
GROUNDWATER
TREATMENT
FULL
ON-SITE
THERMAL
DESTRUCTION
PARTIAL
ON-SITE
THERMAL
DESTRUCTION
AND CAP
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
AND CAP
Clean Water Act Violations
likely
X
Compliance
demonstrated
or feasible
X X X X X
Executive Orders
(EO) for Food
Plain (11988)
Not Applicable X X X X X X
Fish and Wildlife
Coordination Act
(FWCA)
Applicable X X X X X X
Endangerment Species
Act
Applicable X X X X X X
State
Oklahoma Solid Waste
Regulations
Not
Applicable
X X X
Compliance
demonstrated
or feasible
X X X
TABLE 2 (continued)
TABLE OF REMEDIAL ALTERNATIVES COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL LAWS AND REGULATIONS
LAW OR REGULATION ANALYSIS
NO
ACTION
CAP AND
ON-SITE
GROUNDWATER
TREATMENT
CAP AND
OFF-SITE
GROUNDWATER
TREATMENT
FULL
ON-SITE
THERMAL
DESTRUCTION
PARTIAL
ON-SITE
THERMAL
DESTRUCTION
AND CAP
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
AND CAP
Oklahoma Hazardous
Waste Regulations
Not Applicable X X x x
Compliance
demonstrated
or feasible
X x
Oklahoma Clean Air
Act (CAA)
Violations
likely
X
Compliance
demonstrated
or feasible
X X X X X
Oklahoma Water
Quality Standard
Violations
likely
X
Compliance
demonstrated
or feasible
x x x x x
Local
Local Permits Not
Applicable
x x x x x x
TABLE 3
COMPARISON OR REMEDIAL ALTERNATIVES
COMPASS INDUSTRIES
SUPERFUND SITE
ALTERNATIVES
COMPLIES
WITH
ARARS
REDUCES
SHORT
TERM
EFFECT
LONG
TERM
EFFECT
IMPLEMENT-ABILITY
COST
$ MILLION
INIT. REPL.
COMMUNITY
ACCEPT.
STATE
ACCEPT.
OVERALL
PROTECT
MOB. TOX. VOL. OF HH&E
1. NO ACTION - - - - - - - - - - - - + + 1 0 - - - -
2. CAP & ON-SITE
GW TREATMENT + + 0 0 0 + 0 12 5 + 0 +
3. CAP & OFF-SITE
GW TREATMENT + + 0 0 0 + 0 13 5 + - +
4. FULL ON-SITE
THERMAL
DESTRUCTION
GW TREATMENT
+ + + + + + + + - + + - 339 0 - - + +
5. PARTIAL ON-SITE
THERMAL
DESTRUCTION, CAP,
& GW TREATMENT
+ + + 0 - + - 17 0 - - +
6. PARTIAL OFF-SITE
THERMAL
DESTRUCTION, CAP,
& GW TREATMENT
+ + + 0 - - + - 45 0 - - +
TABLE 4
COST SUMMARY OF REMEDIAL ALTERNATIVES
ALT. 1
NO
ACTION
ALT. 2
CAP AND
ON-SITE GW
TREATMENT
ALT. 3
CAP AND
OFF-SITE GW
TREATMENT
ALT. 4
FULL ON-SITE
THERMAL
DESTRUCTION,
AND GW
TREATMENT
ALT. 5
PARTIAL
ON-SITE
THERMAL
DESTRUCTION,
CAP AND GW
TREATMENT
ALT. 6
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
CAP AND GW
TREATMENT
Total Capital &
Implementation
Cost ($)
374,638 9,255,526 9,288,548 336,806,813 14,676,999 41,446,622
Annual O&M
Cost ($)
31,590 272,830 360,280 254,430 272,830 360,280
Total Present
Worth ($)
672,435 11,827,271 12,684,877 339,205,303 17,248,944 44,842,951
Replacement
Cost ($)
0 5,000,000 5,000,000 0 0 0
APPENDIX B
Compass Industries Landfill Site
Tulsa, Oklahoma
Responsiveness Summary
This Community relations responsiveness summary is divided into two sections:
Section I: Background on Community Involvement and Concerns. This section
provides a brief history of community interest and concern raised during the
remedial planning activities on the Compass Industries Superfund site.
Section II: Summary of Major Comments Received during the Public Comment Period
and the EPA Responses to the Comments. Both written and spoken
comments are categorized by topics. EPA responses to these relevant
major topics are also presented.
I. Background on Community Involvement
The Compass Industries Landfill site is located in a sparsely populated area of west
Tulsa, Oklahoma. The community of Berryhill and the city of Sand Springs are within
two miles of the site. An elementary school lies within one-half mile and a major
regional park is immediately adjacent to the site.
Local residents and officials have long expressed concern regarding open burning
and other poor practices at the site. The smoke led citizens and local officials to
request studies to determine potential hazards at the site. The State began extensive
air and water sampling in 1983. EPA also performed sampling and no immediate
health hazards were identified.
The Berryhill Citizens for a Cleaner Environment, organized by residents reacting
primarily to smoke from the site, pressed for remedial action.
In May 1983 the site was evaluated as a possible candidate for inclusion on the
National Priorities List under the Superfund law. The Compass site was included on
the list in August 1983.
The preliminary investigation work began at the site in October 1983. The
underground fires stopped burning in October 1984.
On the afternoon of August 18, 1987, EPA staff members met with Tulsa City Officials
to brief them on the findings of the remedial investigation and feasibility studies, to
describe the various remedial alternatives considered, and to describe EPA's
preferred remedy.
2
Present were Major Dick Crawford; John Selph, Tulsa County Commissioner; Kieth
Francis representing Congressman Jim Inhofe; Sharon Keasler representing Senator
Don Nickles; Mike Wright and Jerry Cleveland of the Tulsa City-County Health
Department; R. Fenton Rood and Dennis Hrebec of the Oklahoma State Department
of Health; Patrick Boulder, Houston Adams, Louis Van Landingham, Priscilla Harris
and Herb Van Fleet of the City of Tulsa; Jennifer Kreel and Susan Young of INCOG;
and William Cox and Kenneth Hill of the City of Sand Springs.
Issues raised include costs of the various alternatives, efficiency of the EPA preferred
alternative and various technical questions.
At 7:00 pm on the evening of August 18, 1987, the public meeting began in the
Berryhill School Auditorium. Representatives of EPA and OSDH made presentations,
listened, and responded to public comments. Some 65 people attended.
II. Summary of Major Comments Received during the Public Comment Period and the
EPA Responses to the Comments
1. Comment: Will any drainage or erosion problems along Avery Drive be caused by the
remedial action at the Compass Industries site?
Response: No, Drainage and erosion issues will be addressed and provided for in
the design phase.
2. Comment: Can 32 acres be covered effectively by a synthetic liner?
Response: It is technically feasibility to cover 32 acres with a liner. Sites as large as
100 acres have been covered effectively with a synthetic liner. The engineering and
implementation of installing the liner will be addressed in the design phase.
3. Comment: Will the seeps going into the Arkansas River be treated?
Response: No, the seeps themselves will not be treated. The groundwater on-site
which generates the seeps may be treated in the future if necessary.
4. Comment: What quality standards will the treated water be required to meet?
Response: All State and Federal standards.
5. Comment: What volume of water will be treated?
Response: Treatment of groundwater is deferred pending an evaluation of the
effectiveness of the cap. The feasibility study estimates approximated a 263,000
gallon yield per year from the aquifers which discharge off-site. These estimates,
calculated over the 30-year operation and maintenance period amount to a total of
approximately 7,890,000 gallons.
3
Considering the majority of contaminants are within the upper zone of the aquifer
system, actual volume and timeframe for treatment should be considerably less.
6. Comment: If the landfill is capped, won't the water dry up eventually?
Response: In theory, the water in the perched or contained water bearing zone within
the landfill area should dry up. Treatment of the contaminated liquids, if found
necessary, in the landfill area will additionally reduce the potential for offsite migration
of contaminants.
7. Comment: Will the groundwater have to be airstripped? Will the resulting sludge be
landfilled on-site?
Response: Air stripping is a potential treatment alternative, however, a specific
technology is not specified in the Feasibility Study. If air stripping was selected
sludges could be landfilled on-site.
8. Comment: What protection will there be against air pollution?
Response: Construction of the cap remedy is not anticipated to generate any
uncontrollable adverse air emissions and will reduce the potential for future emissions.
9. Comment: How can the land be used if the cap and groundwater treatment remedy is
implemented?
Response: Future land use considerations will be evaluated in the upcoming design
phase based on the needs of protection of the cap.
10. Comment: How far along is EPA with identifying PRPs?
Response: Approximately 20 PRPs have been identified.
11. Comment: What is EPA's timetable for implementing a remedy at the site?
Response: Design, procurement of contractors and construction is estimated to take
approximately 3 years.
12. Comment: Why is there such a large difference in the the State recommended $1.6
million cap remedy and the EPA $13 million cap remedy.
Response: No basis for a $1.6 million cap remedy has been submitted by the State.
The construction cost estimates submitted as the official public comments by the
Oklahoma State Department of Health
4
(OSDH) for a the cap without liner is represented as costing $3,412,944. The States
proposed cap design is similar to the EPA RCRA cap design, less the synthetic liner.
The estimated construction costs of the EPA RCRA cap, with liner, is $4,256,000.
The balance of the $12 million cost estimate consists of groundwater collection and
treatment, contingency, implementation, and operation and maintenance costs.
Therefore the difference in costs is only $843,056. A more detailed cost comparison
is provided on page 11.
13. Comment: A liner would produce toxic fumes if the underground fires started again.
Response: By reducing oxygen within the landfill interior the synthetic liner will reduce
the potential for reoccurring underground fires. The possibility of the liner catching fire
is remote since it is contained within a 5' layer of compacted earthen material.
14. Comment: More engineering should be conducted prior to the selection of remedies.
Response: EPA disagrees with this viewpoint. Congress, through SARA, has
structured the Superfund program to-prevent the unnecessary expenditure of funds.
Detailed engineering information, necessary for the design stage, is not needed to
select a remedial concept.
15. Comment: The Compass Industries site should be considered an improperly closed
solid waste disposal facility and should be closed as required in the Oklahoma Solid
Waste Management Act.
Response: EPA disagrees. The Compass Industries site was permitted to accept
solid and hazardous wastes and was a major landfill in the Tulsa area. Documents
indicate in excess of 40,000 barrels of refinery sludges and waste liquids were
disposed of at the Compass Industries site. In addition, analytical data gathered
during the Remedial Investigation verifies the presence of hazardous waste on-site as
well as migrating off-site. Due to the presence of hazardous waste and the current
and potential migration of contaminants off-site the closure of the site in accordance
with Subtitle C of the Resource Conservation and Recovery Act, which requires a cap
with liner, is relevant and appropriate.
16. Comment: The low levels of compounds migrating off-site from the seeps establishes
a carcinogenic risk factor of 10-5 (1 in 100,000).
Response: The EPA goal is to reduce carcinogenic risk to 10-6 (1 in 1,000,000) for
groundwater.
5
17. Comment: The levels of compounds in the seeps do not cause a significant increase
of contaminants in the surface water of the Arkansas River.
Response: Levels of contaminants in the Arkansas river have no bearing on the
authority of EPA to respond to the release or threat of release of contaminants from
the Compass Industries site. The potential exists for direct contact with and ingestion
of the seeps themselves.
18. Comment: A cap without a liner can meet all applicable or relevant and appropriate
requirements.
Response: EPA agrees. However, if technically feasible a cap with a liner has
additional technical advantages and provides greater protection of public health and
the environment. A liner would be less permeable and would further reduce the
infiltration of surface water. The long term advantage to the liner is that less water
would be generated from the seeps.
19. Comment: Acute and chronic bioassays or multi series bioassays should have been
conducted as well as tests to determine bioaccumilation and bioconcentration of
toxics at the Compass Industries site.
Response: EPA disagrees. EPA typically relies on historical toxicological
information for evaluating contaminant levels at Superfund sites. The response
authority under CERCLA as amended by SARA extends beyond current effects from a
site to include potential releases (and effects) of contamination therefore biological
studies although informative, are not required for selecting a remedy.
20. Comment: No Endangerment Assessment on the Compass Industries site has been
available for review and no Health Assessment has been accomplished for the
Compass Industries site. Therefore no balancing of any such risks against the costs of
the remedies is possible.
Response: EPA disagrees. The information developed in the Endangerment
Assessment was in fact incorporated and utilized in the Feasibility Study and available
for public comment, although not under separate cover. Documents on which the
Record of Decision is based are included in the Administrative Record which is
available for public review prior to the signing of the Record of Decision. A Health
Assessment is not required prior to the signing of a Record of Decision. Adequate
data has been gathered with regards to potential health impacts on which to make a
selection of a remedy. The Agency for Toxic Substances and Disease Registry
(ATSDR) concurs with the EPA determination of the need to respond to the current
and potential release of contaminants from the site. ATSDR is currently evaluating the
information on the Compass Industries site and will provide a Health Assessment
which can be utilized during the upcoming design phase.
6
21. Comment: What long term impacts (20 to 30 years) does the site pose?
Response: The potential for future fires and continued off-site migration of
contaminants pose adverse human health and environmental impacts. Other impacts
which the site may pose cannot be effectively predicted. A RCRA cap and
groundwater treatment would mitigate these problems as well as most of the unseen,
long term problems.
22. Comment: Is there an approved Federal and/or State hazardous waste dump in the
State of Oklahoma?
Response: No, at this time there are no approved Federal and/or State hazardous
waste disposal sites in Oklahoma. The Lone Mountain site near Waynoka, Oklahoma
is not in compliance with its permitting requirements. This is not to say that when
remedial action begins at a site there will not be a Federal and/or State approved
disposal facility in the State of Oklahoma.
23. Comment: Is Superfund a congressional appropriation? Does it have a 12 month
limitation on it or is it continuous with an option?
Response: Superfund under SARA is a congressional appropriation which contains
$8.5 billion for a 5 year period. This 5 year period began in 1986.
24. Comment: How much of the $62 million in Superfund monies that has been spent by
EPA Region VI went for actual clean ups as opposed to studies?
Response: Since the program began, over $250 million has been obligated within the
Region VI jurisdiction for Superfund evaluations and cleanups when the commitments
by responsible parties are added to the dollars used from the fund. Of this sum, $200
million is for the design and construction of remedies however this figure cannot be
compared to the remaining $50 million. The Region has found that, in many instances,
responsible parties do not commit to performing site cleanups until EPA's evaluations
are completed and a decision regarding site clean up approach is made. In addition,
about half of the Regions Superfund sites are still under study. For these two reasons
a simple ratio of the amount of monies spent on cleanups versus studies is misleading
and inaccurate.
25. Comment: An adequate health risk assessaent of the existing health risks at the site
and determination of the health risks of the remedial alternatives has not been
conducted.
Response: A qualitative assessment of the potential public health threats in the
absence of remedial action was conducted. This was accomplished in the Compass
Industries Landfill Endangerment Assessment dated July 10, 1987, and amended
August 10, 1987, under the Cooperative Agreement with OSDH.
7
Response: EPA disagrees. Adequate data has been gathered and the evaluations
have been conducted to satisfy the above mentioned guidance documents and
statutory requirements on which to base a decision.
27. Comment: "The Feasibility Study is fundamentally flawed because it fails to consider
lower cost remedial operations that provide protection similar to more expensive
options being considered, contrary to SARA and F.S. guidance requirements."
Response: EPA disagrees with this comment. Numerous alternatives with a wide
range of costs were evaluated in the Feasibilty Study. Most of these alternatives were
eliminated because they could not meet the intent of SARA and the NCP and were not
cost effective. EPA has selected the most cost-effective and technically applicable
alternative.
28. Comment: "The Feasibility Study is fundamentally flawed because it fails to properly
evalute the risk to public health."
Response: EPA disagrees. An endangerment assessment was conducted and
incorporated into the ROD. EPA feels that this endangerment assessment properly
evaluates the risk to public health and adequately supports the proposed remedial
action.
29. Comment: "The Feasibility Study fails to properly analyze and apply applicable or
relevant and appropriate requirements (ARARs)."
Response: EPA disagrees. The applicable or relevant and appropriate requirements
(ARARs) are listed in Table 7-3 of the Feasibility Study. These ARARs were analyzed
and used to evaluate the various alternatives studied.
30. Comment: "Sun was deprived of a reasonable opportunity to participate in the
establishment of an administrative record."
Response: EPA believes that Sun was given sufficient time to evaluate the RI/FS and
to participate in the establishment of an administrative record. In addition, Sun has
been aware of the site activities since at least August 1984. At this time a letter was
sent to Sun requesting information on the site. This letter requested information on
waste generation, transport, and disposal. Public notice of the upcoming comment
period was issued July 22, 1987. Four weeks were allowed for the public comment
period. The comment period began on August 5, 1987, and was orginally scheduled
to close on August 26. An extention to the public comment period changed the closing
date to September 2.
31. Comment: “Failure of the Remedial Investigation to conform to EPA's guidance on
Remedial Investigation under CERCLA procedures for data validity and sufficiency."
Response: EPA disagrees. The Remedial Investigation guidance was adequately
followed and a comprehensive study was conducted.
8
32. Comment: "Quality assurance and quality control measures at the laboratory are not
documented."
Response: EPA disagrees. Quality assurance and quality control procedures were
adequately followed and are documented in a QA/QC plan approved by EPA in April
1984. Actual QA/QC results are included in the Administrative Record.
33. Comment: "Data used in the RI/FS is questionable."
Response: EPA disagrees. Adequate quality data was compiled in which to conduct
a thorough Feasibility Study and to base a remedial action decision. The quality of
this data was assured through the use of a QA/QC plan.
34. Comment: "EPA's basis (air route) for listing this site on the NPL is not borne out by
the RI/FS."
Response: Although air sampling showed minimal respiratory hazard, analysis of
on-site waste justifies need for a response/ remedial action. Analytical results of the
on-site waste is documented in the RI/FS.
35. Comment: "The Remedial Investigation did not conform to the technical workplan
submitted by Mathes on April 25, 1986." (Drilling logs not submitted, etc.)
Response: EPA disagrees. Documentation for the drilling which took place during
the remedial investigation is contained in Appendices A-E of the Remedial
Investigation Report.
36. Comment: "Groundwater data from the lower aquifer is questionable and may have
been introduced by well drilling activity." (This is assumed to refer to old abandoned
petroleum wells existing onsite).
Response: The Remedial Investigation Report indicates that oil well drilling in the
vicinity of the site may have influenced contamination of the lower aquifer. This was
considered in the evaluation of appropriate remedial actions.
37. Comment: "The quantity of samples is insufficient for a meaningful site evaluation."
Response: This is incorrect. An adequate number of samples were collected to
properly evaluate the risks posed by the site and to support the proposed action.
38. Comment: "The Feasibility Study does not address technical feasibility or remedial
options as required by SARA and EPA F.S. Guidance.
9
Response: This is incorrect. The technical feasibility of the remedial options is
covered in section 7.2 of the Feasibility Study. Other references to the technical
feasibility of the alternatives can be found under the title of implementability.
39. Comment: "Cost estimates for remedial alternatives used in the F.S. ar imprecise, do
not reflect likely actual costs of the options and therefore do not allow for meaningful
comparison of costs as required by SARA and EPA's F.S. guidance."
Response: This is incorrect to the extent that the F.S. has adequately evaluated the
cost of the alternatives to enable the selection of the most cost effective alternative.
The intent of the FS cost estimates is to evaluate relative costs and not to give the
level of cost expected in a detailed design report. As indicated in the feasibility study,
the costs for the alternatives are based on cost estimates of -30% to +50%.
40. Comment: "The quality of the background data as reported in the remedial
investigation is admittedly questionable."
Response: EPA disgrees. Due to the random disposal techniques used at the site
and varying hydrogeologic conditions, various contaminant levels were detected at
several different locations. Some background samples do contain higher levels of
some specific compounds compared to other sampling locations. This merely
indicates contamination levels and compounds vary throughout the site.
41. Comment: "The quality of the data reported in the Remedial Investi ation on PCB
contamination is admittedly questionable."
Response: EPA disagrees. The presence of PCBs is documented in two separate
sampling events and is viewed as being reliable data.
42. Comment: “The lack of chain of custody documentation is contrary to EPA's
requirements."
Response: An established chain of custody procedure was followed. This information
is in the Administrative Record.
43. Comment: "The RI and FS fail to analyze and rank compounds present on-site for
potential adverse health effects, as required by EPA RI and FS guidance."
Response: EPA disagrees. Selected indicator compounds, chosen on their potential
for indicating adverse health effects, are indicated in the summary of the
endangerment assessment in the feasibility study.
44. Comment: "Neither the RI nor the FS addresses information gaps that are necessary
to identify and remediate any potential aquifer cross contamination prior to selection
and implementation of the remedy."
10
Response: This information is not considered necessary for implementing the
proposed remedy. Since the only use of the groundwater by the surrounding residents
is upgradient from the site, the need to remediate potential aquifer cross
contamination was not evaluated. (No downgradient groundwater users exists
because the aquifers in question discharge to the surface just north of the site.
45. Comment: "The RI/FS reports fail to follow the format prescribed in EPA guidance."
Response: EPA disagrees. The RI/FS and endangerment assessment follow the
format prescribed in EPA guidance.
11
COMPASS INDUSTRIES
OSDH vs EPA REMEDY COST
COST COMPONENT
OSDH “D” CAP
COST ESTIMATE
EPA “C” CAP
COST ESTIMATE
COST
DIFFERENC
E
Site Development 0 150,000
Fencing 0 47,700
Groundwater Monitoring 0 153,000
Air Monitoring 0 6,500
Cap 3,412,944 4,256,000 843,056
Gas Collection &
Venting
0 36,000
Groundwater Collection
System
0 621,600
Mobilization, Bonds,
Insurance
0 263,540
Health & Safety 0 368,956
Contingency (Bid) 0 790,620
Contingency (Scope) 0 1,054,160
Engineering 341,294 500,000 (A) 158,706
Legal 0 387,404
Construction
Management
273,035 619,846 346,811
Total Capitol &
Implementation
4,027,273 9,255,526
Annual O&M (Includes
Groundwater Treatment)
0 272,830
Total Present Worth 4,027,273 11,827,271 7,799,988
(A) Includes Groundwater Collection & Treatment Design
APPENDIX C
MEMORANDUM
DATE September 15,1987
FROM: Senior Regional Representative
Regional Office for Health Response
ATSDR/ROHRHVI
TO: Paul Sieminiskj
Remedial Project Manager
ALONM Section (6H-SA)
The Agency for Toxic Substance and Disease Registry (ATSDR) has been requested by
the Environmental Protection Agency (EPA) to review and evaluate the Remedial
Investigation/Feasibility Study/Endangerment Assessment data that was generated from
the Compass Industries Superfund Site located in Tulsa, OK.
Currently the ATSDR is reviewing these documents to provide EPA with a comprehensive
Health Assessment for this site.
Based on our review to date, the ATSDR, Regional Office for Health Response in
consultation with staff at ATSDR–Headquarters is of the opinion that the Compass Industry
Superfund Site does pose a current and potential public health threat.
Initial indications are that ATSDR recommendations will be directed toward unacceptable
risks associated with direct public contact and/or unintentional fires at this site.
APPENDIX D
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 10/03/75
Document Type Type Appeal from Decision of City Commission of Tulsa,
Okla.
Originator Troye Kennon
Originator - Affiliation Affiliation Atty. - Compass Industries, Inc.
Recipient Dist. Ct., Tulsa County, Okla.
Recipient - Affiliation
Description Appeal of Tulsa City Commission ruling
Number of Pages 5
Document Number Sequence
Document Date 03/08/76
Document Type Memorandum
Originator Dennis Bergstrom
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Health Dept. Files
Recipient - Affiliation
Description March 5, 1976 inspection of landfill
Number of Pages 1
Document Number Sequence
Document Date Undated, covers inspections from 1/12/76 to 01/19/76
Document Type
Originator Dennis Bergstrom
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Health Dept. Files
Recipient - Affiliation
Description Fires at Chandler Land Fill Jan. 12 through Jan. 19, 1976
Number of Pages 3
Document Number Sequence
Document Date 04/12/76
Document Type Memorandum
Originator Dennis Bergstrom
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Health Dept. Files
Recipient - Affiliation
Description Summary of Inspections 1/12/76 to 4/12/76
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 09/27/76
Document Type Informational Letter
Originator Gary Cox
Originator - Affiliation Public Health Atty. for Tulsa City/Co. Health Dept.
Recipient Doyle and Holmes Law Offices
Recipient - Affiliation Receiver for Compass Industries
Description Informs recipient that Health Dept. seeks their compliance
with state law Re: land fill closure
Number of Pages 1
Document Number Sequence
Document Date 06/15/82
Document Type Summary reports and worksheets
Originator Unknown
Originator - Affiliation
Recipient Unknown
Recipient - Affiliation
Description Computes Hazard Ranking System score
Number of Pages 10
Document Number Sequence
Document Date 09/20/82
Document Type Inspection Report, U.S. E.P.A. Form T2070-3 (10-79)
Originator David Anderson
Originator - Affiliation U.S. E.P.A.
Recipient U.S. E.P.A. Files
Recipient - Affiliation
Description Potential Hazardous Waste Site Inspection Report
Number of Pages 14
Document Number Sequence
Document Date 11/05/82
Document Type Memorandum
Originator Jinks Martin, Jr.
Originator - Affiliation Citizen
Recipient Jerry Cleveland
Recipient - Affiliation Tulsa City/County Health Dept.
Description Complaint about fumes and smoke
Number of Pages 1
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 12/20/82
Document Type General Complaint Form
Originator Martin Bousum
Originator - Affiliation Citizen
Recipient Health Dept. Files
Recipient - Affiliation Tulsa City/Co. Health Dept.
Description Describes problems of Mr. Martin Bousum
Number of Pages 1
Document Number Sequence
Document Date 12/21/82
Document Type Complaint Report
Originator Darrell Roeder
Originator - Affiliation Citizen
Recipient Health Dept. Files
Recipient - Affiliation Tulsa City/Co. Health Dept.
Description Complaints of a Mr. Darrell Roeder
Number of Pages 1
Document Number Sequence
Document Date 01/03/83
Document Type Complaint Report
Originator Martin Bousum
Originator - Affiliation Citizen
Recipient Health Dept. Files
Recipient - Affiliation Tulsa City/Co. Health Dept.
Description Details, complaints of a Mr. Martin Bousum
Number of Pages 1
Document Number Sequence
Document Date 01/03/83
Document Type Complaint Report
Originator Thorunn M. Gilstrap
Originator - Affiliation Citizen
Recipient Heal Dept. Files
Originator - Affiliation Tulsa City/Co. Health Dept.
Description Complaints of Mr. Thorunn M. Gilstrap
Number of Pages 1
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 01/14/83
Document Type Letter
Originator Mark S. Coleman
Originator - Affiliation State Dept. of Health
Recipient Dr. Edgar Cleaver
Recipient - Affiliation Tulsa City/County Health Dept. (TCCHD)
Description TCCDH as plaintiff in any action brought by Tulsa Co.
Dist. Atty.
Number of Pages 1
Document Number Sequence
Document Date 01/17/83
Document Type Resolution
Originator Terry Young
Originator - Affiliation Tulsa County Board of County Commissioners
Recipient
Recipient - Affiliation
Description Requests Dist. Atty. To initiate action abating the public
nuisance at Tulsa Refuse Dump No. 1
Number of Pages 1
Document Number Sequence
Document Date 01/28/83
Document Type Petition filed in Tulsa County Dist. Ct.
Originator Tulsa County Board of County Commissioners, Tulsa
City/County Health Dept., State of Okla.
Originator - Affiliation
Recipient Filed in Tulsa County Dist. Ct.
Recipient - Affiliation
Description Requests the court hold hearings on alleged violations
Number of Pages 8
Document Number Sequence
Document Date 03/28/83
Document Type Memorandum
Originator Gary S. McDonald
Originator - Affiliation Solid Waste Division, Okla. State Dept. of Health
Recipient Health Dept . Files
Recipient - Affiliation
Description Describes sampling conducted 3/23/83
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 03/28/83
Document Type Memorandum
Originator Joseph Dunagan
Originator - Affiliation Industrial Waste Division, Okla. State Dept. of Health
(OSDH)
Recipient Richard Thompson
Recipient - Affiliation Solid Waste Division (OSDH)
Description Reconnaissance of land fill prior to 3/28/83
Number of Pages 2
Document Number Sequence
Document Date 03/28/83
Document Type Air quality evaluation of land fill fire
Originator Air Quality Staff, Tulsa City/County Health Dept.
Originator - Affiliation TCCHD
Recipient Health Dept. Files
Recipient - Affiliation
Description Summarizes monitoring activities from 10/26/82 to 1/28/83
Number of Pages 28
Document Number Sequence
Document Date 04/26/83
Document Type Press Release
Originator Eddie Lee
Originator - Affiliation U.S. E.P.A.
Recipient
Recipient - Affiliation
Description Press release stating U.S. E.P.A. will conduct further air
quality tests
Number of Pages 1
Document Number Sequence
Document Date 06/09/83
Document Type Record
Originator Cynthia Bachunas
Originator - Affiliation Unknown
Recipient Russell Bartley (U.S. E.P.A.) and Ken Raymond (Okla.
State Dept. Health)
Recipient - Affiliation
Description Hazard Ranking System
Number of Pages 29
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 06/10/83
Document Type Section 3007 Request for Information
Originator Dick Whittington
Originator - Affiliation U.S. E.P.A.
Recipient Bill Jackson
Recipient - Affiliation Owner of Compass Industries landfill
Description Possible receipt of hazardous waste
Number of Pages 3
Document Number Sequence
Document Date 09/02/83
Document Type 3007 Request for Information
Originator Allyn M. Davis
Originator - Affiliation U.S. E.P.A.
Recipient John Deatherage
Recipient - Affiliation Standard Industries
Description Wastes received at Compass and on Standard Industries’
purchase of site
Number of Pages 3
Document number Sequence
Document Date 01/10/84
Document Type Letter
Originator Russell Bartley
Originator - Affiliation U.S. E.P.A.
Recipient Fenton Rood
Recipient - Affiliation Okla. State Dept. of Health
Description Compass Industries Workplan
Number of Pages 3
Document Number Sequence
Document Date 03/01/84
Document Type Quality Assurance Project Plan
Originator Okla. State Dpt. Of Health
Originator - Affiliation
Recipient Health Dept. Files
Recipient - Affiliation
Description Quality Assurance project Plan
Number of Pages 114
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 04/18/84
Document Type Memorandum
Originator Paul Sieminski, Project Officer
Originator - Affiliation U.S. E.P.A. Region (6AW-SP)
Recipient Ray Lozano, Coordinator
Recipient - Affiliation Office of Quality Assurance
Description QAPP-Compass Cooperative Agreement
Number of Pages 3
Document Number Sequence
Document Date 05/07/84
Document Type Letter
Originator Paul Sieminski
Originator - Affiliation U.S. E.P.A.
Recipient Fenton Rood
Recipient - Affiliation Okla. State Dept. of Health
Description Approval of 3/1/84 version of Quality Assurance Project
Plan
Number of Pages 1
Document Number Sequence
Document Date 06/15/84
Document Type Health and Safety Plan
Originator David Wharton
Originator - Affiliation Okla. State Dept. of Health
Recipient Health Dept. files
Recipient - Affiliation
Description Health and Safety Plan for remedial Investigation
Number of Pages 7
Document Number Sequence
Document Date 08/20/84
Document Type Minutes of Public Meeting
Originator Okla. State Dept. of Health
Originator - Affiliation
Recipient Health Dept. Files
Recipient - Affiliation
Description Minutes of public meeting held 8/20/84
Number of Pages 3
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 11/28/84
Document Type Letter
Originator John R. Totin
Originator - Affiliation Ecology and Environment, Inc.
Recipient Ken Burns
Recipient - Affiliation Okla. State Dept. of Health
Description Describes monitoring well installation and sampling
Number of Pages 14
Document Number Sequence
Document Date 01/11/85
Document Type Letter of response
Originator Dick Whittington, Regional Administrator Region VI
Originator - Affiliation U.S. E.P.A.
Recipient I.J. Ramsbottom, Environmental Clearance Officer
Recipient - Affiliation Dept. Housing & Urban Development
Description HUD’s Draft Environmental impact Statement
Num er of Pages 4
Document Number Sequence
Document Date 01/23/85
Document Type Letter
Originator Mike Wright/Solid & Industrial Waste
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Ken Burns - Superfund Projects
Recipient - Affiliation Okla. State Dept. of Health
Description Steps to contact access to landfill
Number of Pages 2
Document Number Sequence
Document Date 02/00/85
Document Type Preliminary Report
Originator Okla. State Dept. of Health
Originator - Affiliation State agency
Recipient For Okla. State Dept. of Health files
Recipient - Affiliation State agency
Description Preliminary Report - Compass Industries
Number of Pages 9
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 03/85
Document Type Magazine articles, editor’s pg., table of contents
Originator Maria Weldings, Patsy Varnell
Originator - Affiliation Berryhill Citizens for Safe Environment
Recipient Oklahoma Sierran
Recipient - Affiliation Sierra Club/Okla. Chp.
Description Historical overview of Compass Landfill
Number of Pages 3-4/4
Document Number Sequence
Document Date 04/03/85
Document Type Newspaper article
Originator Julie DelCour
Originator - Affiliation Tulsa World Newspaper - Staff
Recipient Public
Recipient - Affiliation
Description Dismissal of $150 million Lawsuit
Number of Pages 1
Document Number Sequence
Document Date 04/22/85
Document Type Letter
Originator Ken Burns - Superfund Project Coordinator
Originator - Affiliation Okla. State Dept. of Health
Recipient Thomas J. DiRito
Recipient - Affiliation Bellaman Community Development
Description Shenandoah Project - amid Springs, Okla.
Number of Pages 2
Document Number Sequence
Document Date 06/12/85
Document Type Sampling Plan
Originator Okla. State Dept. of Health
Originator - Affiliation State agency
Recipient For Dept. of Health files (Okla.)
Recipient - Affiliation State Agency
Description Groundwater monitoring sampling plan
Number of Pages 13
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 10/00/85
Document Type Planning - Study Reports
Originator Okla. State Dept. of Health Waste Mgmt. Service
Originator - Affiliation
Recipient For Dept. of Health files (Okla.)
Recipient - Affiliation State agency (Okla.)
Description Health and Safety Plan - RI
Number of Pages 33
Document Number Sequence
Document Date Undated apparently March 1986
Document Type Trenching Sampling Plan
Originator Okla. State Dept. of Health
Originator - Affiliation
Recipient Health Dept. Files
Recipient - Affiliation
Description Plan for trenching and sampling
Number of Pages 9
Document Number Sequence
Document Date 04/28/86
Document Type Technical Work Plan
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation
Description Plan Re: exploration services for RI
Number of Pages 27
Document Number Sequence
Document Date 05/01/86
Document Type News release
Originator Okla. State Dept. of Health
Originator - Affiliation State agency
Recipient Public
Recipient - Affiliation
Description Historical background Re: Compass landfill
Number of Pages
Document Number Sequence 2
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 05/13/86 - 05/31/86
Document Type Record
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation
Description Daily driller’s record
Number of Pages 13
Document Number Sequence
Document Date 05/16/86
Document Type Letter of Review
Originator Douglas Kent
Originator - Affiliation MDK Consultants
Recipient Thomas DiRito
Recipient - Affiliation Bellamah Community Development
Description Review of proposed monitoring plan
Number of Pages 14
Document Number Sequence
Document Date 05/28/86
Document Type Letter
Originator Thomas J. DiRito - Tulsa Mgr.
Originator - Affiliation Bellamah Community Development
Recipient Hal Cantwell - Environmental Specialist
Recipient - Affiliation Okla. State Dept. of Health
Description Review of proposed monitoring plan
Number of Pages 1
Document Number Sequence
Document Date Undated
Document Type Report
Originator Unknown - probably U.S. E.P.A. (6)
Originator - Affiliation U.S. E.P.A. Region VI
Recipient U.S. E.P.A. Region VI - Compass File
Recipient - Affiliation
Description General overview of site
Number of Pages 13
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 14/01/87
Document Type Letter
Originator Allyn M. Davis, Director
Originator - Affiliation Hazardous Waste Mgtment Service/U.S. E.P.A.
Recipient Mark Coleman, Deputy Commissioner
Recipient - Affiliation Okla. State Dept. of Health
Description Correspondence Re: RI/FS
Number of Pages 1
Document Number Sequence
Document Date 04/03/87
Document Type Letter; sampling plan
Originator Hal Cantwell, ES
Originator - Affiliation Superfund Program/Solid Waste Division, Okla. State
Dept. of Health
Recipient Paul Sieminski (6H-SS)
Recipient - Affiliation U.S. E.P.A.
Description Industries Dioxin Testing
Number of Page 6
Document Number Sequence
Document Date 04/15/87
Document Type Memorandum
Originator R. Fenton, Rood, Director
Originator - Affiliation Solid Waste Division
Recipient Mark Coleman, Deputy Commissioner
Recipient - Affiliation Environmental Health Services
Description March Progress Report
Number of Pages 3
Document Number Sequences
Document Date 05/13/87
Document Type Cover letter, Action Specific Requirements
Originator Hal Cantwell/Environmental Specialist
Originator - Affiliation U. S. E. P. A.
Recipient Carl Edlund, Chief
Recipient - Affiliation U. S. E. P. A.
Description Action-specific State of Okla. ARARs
Number of Pages 5
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 05/21/87
Document Type Cover letter, Analytical Results
Originator Dale Markley, Sr., Hydrogeologist
Originator - Affiliation Jn. Mathes & Assoc., Inc.
Recipient Hal Cantwell
Recipient - Affiliation Okla. State Dept. of Health
Description Analytical Results - Dioxin & Furans/RI/FS
Number of Pages 19
Document Number Sequence
Document Date 07/10/87
Document Type Assessment
Originator Dr. Raymond Harlison - Dept. Medical Science
Originator - Affiliation Univ. of Ark.
Recipient Jn. Mathes & Assoc., Inc.
Recipient - Affiliation
Description Endangerment Assessment
Number of Pages 111
Document Number Sequence
Document Date 07/13/87
Document Type Report by engineering firm for Compass
Originator John Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State agency
Description RI Report for Compass Industries/Vol. I
Number of Pages 156 - 2 pgs. “References”
Document Number Sequence
Document Date 07/13/87
Document Type Appendix -R/I Report/Compass Industries (A-E)
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State agency
Description Appendix for Engineering logs Vol II
Number of Pages 99
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 07/13/87
Document Type Appendix R/I Report/Compass Industries (F)
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State Agency
Description Appendix for Analytical Data Vol III
Number of Pages 223
Document Number Sequence
Document Date 07/13/87
Document Type Appendix - P/I Report (F continued)
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State Agency
Description Appendix for Analytical Data Vol. IV
Number of Pages 228
Document Number Sequence
Document Date 07/13/87
Document Type Report
Originator John Mathes & Assoc., Inc.
Originator - Affiliation
Recipient Ok. State Dept. Health
Recipient - Affiliation
Description Feasibility Study Report
Number of Pages 121
Document Number Sequence
Document Date 08/10/87
Document Type Assessment
Originator John Mathes & Assoc., Inc.
Originator - Affiliation
Recipient Ok. State Dept. Health
Recipient - Affiliation
Description Endangerment Assessment
Number of Pages 116
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 8/10/87
Document Type Addendum
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation
Recipient OK State Dept. Health
Recipient - Affiliation
Description Addendum - Endangerment Assess. Exhibits A-F
Number of Pages 140
Document Number Sequence
Document Date 08/18/87
Document Type Letter
Originator Jerry Cleveland, Asst. Director
Originator - Affiliation Tulsa City/Co. Health Dept.
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Response to Health Dept.’s recommend.
Number of Pages 1
Document Number Sequence
Document Date 08/18/87
Document Type Memorandum
Originator Betty Jean Reece, Project Officer
Originator - Affiliation U.S. E.P.A. (6) 6H-SS
Recipient U.S. E.P.A. (6) Compass File
Recipient - Affiliation
Description Meeting 08/18/87
Number of Pages 2
Document Number Sequence
Document Date 08/20/87
Document Type Letter
Originator Wm. R. Cox - Dir. Utility Plants/Opera.
Originator - Affiliation City of Sand Springs
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Comments Re: Compass Site
Number of Pages 3
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 08/21/87
Document Type Letter
Originator David Page - Atty.
Originator - Affiliation Boone, Smith, Davis & Hurst - Law Office
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Extension of public comment period
Number of Pages 1
Document Number Sequence
Document Date 08/25/87
Document Type Letter
Originator Hal D. Cantwell, Environ. Special.
Originator - Affiliation OK State Dept. Health
Recipient Carl Edlund, Chief (6H-S)
Recipient - Affiliation SuperFund Program - U.S. E.P.A. (6)
Description Extension - Public Comment Period
Number of Pages 1
Document Number Sequence
Document Date 08/27/87
Document Type Letter
Originator R. Fenton Rood, Dir.
Originator - Affiliation OK State Dept. Health
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Public comments Re: selection of remedy
Number of Pages 5
Document Number Sequence
Document Date 08/27/87
Document Type Letter
Originator Evelyn Reid
Originator - Affiliation Citizen - Tulsa, OK
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Program
Description Response to public meeting
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 08/28/87
Document Type Letter
Originator Shawn Thorton
Originator - Affiliation Citizen - Bartlesvilles, OK
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Program
Description Response to public meeting
Number of Pages 1
Document Number Sequence
Document Date 08/31/87
Document Type Letter
Originator John Selph
Originator - Affiliation Board of Co. Commissioners
Recipient Carl Edlund, Chief
recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description State Health Dept.’s proposed remedy
Number of Pages 2
Document Number Sequence
Document Date 08/31/87
Document Type Letter
Originator Mark Coleman, Deputy Commissioner
Originator - Affiliation OK Dept. of Health
Recipient Robt. Layton, Reg. Admin.
Recipient - Affiliation U.S. E.P.A. Region VI
Description RA alternatives
Number of Pages 1
Document Number Sequence
Document Date 09/01/87
Document Type Letter/attach.
Originator R. Fenton Rood, Director
Originator - Affiliation OK State Dept. Health
Recipient Carl Edlund Chief (6H-S)
Recipient - Affiliation U.S. E.P.A. Region VI
Description Public comments/summary table
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 09/01/87
Document Type Letter
Originator Charles W. Shipley - Atty.
Originator - Affiliation Law Firm - Shipley & Schneider
Recipient Carl Edlunds, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Response to ROD
Number of Pages 3
Document Number Sequence
Document Date 09/02/87
Document Type Letter/attachment
Originator Edward A. Kurent - Atty.
Originator - Affiliation Pepper, Hamilton & Scheetz - Law firm
Recipient, Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (Region VI - 6H-S)
Description Comments on RI/FS Reports
Number of Pages 41
Document Number Sequence
Document Date 09/10/87
Document Type Letter
Originator Jerry Lasker, Exec. Director
Originator - Affiliation Indian Nations Council of Govts.
Recipient Robt. Layton - Regional Admin.
Recipient - Affiliation U.S. E.P.A. Region VI
Description Comments Re: ROD
Number of Pages 3
Document Number Sequence
Document Date 09/28/87
Document Type Letter/attachment
Originator Edward A. Kurent - Atty.
Originator-Affiliation Law firm - Petter, Hamilton & Scheetz
Recipient Carl Edlund/Julie Bozich
Recipient - Affiliation U.S. E.P.A. Region VI
Description Comments Re: RI/FS; unindexed AR docu.
Number of Pages 73
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 09/29/87
Document Type Letter
Originator Mark S. Coleman, Depty. Commiss.
Originator - Affiliation OK State Dept. of Health
Recipient Allyn Davis, Director
Recipient - Affiliation U.S. E.P.A. Region VI
Description Acceptance of ROD
Number of Pages 1
Document Number Sequence
APPENDIX E
September 29, 1987
Allyn M. Davis, Director
Hazardous Waste Management Division
Environmental Protection Agency
Region VI
Dallas, Texas 73202-2733
Dear Dr. Davis:
The Oklahoma State Department of Health (OSDH) has reviewed the Declaration for the
Record of Decision for the Compass Industries site Tulsa, Oklahoma. The OSDH does
concur with the selected remedy detailed in the Declaration. The OSDH looks foward to
continuing to work together with the EPA towards a solution to the problems at the
Compass Industries site.

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EPA/ROD/R06-87/900
1987
EPA Superfund
Record of Decision:
COMPASS INDUSTRIES (AVERY DRIVE)
EPA ID: OKD980620983
OU 01
TULSA, OK
09/29/1987
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
COMPASS INDUSTRIES LANDFILL
TULSA COUNTY, OKLAHOMA
SEPTEMBER 1987
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Compass Industries, Tulsa County, Oklahoma.
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for this site developed in
accordance with Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and the National Contingency Plan (40 CFR Part 300).
The State of Oklahoma has concurred on the selected remedy. (Letter attached)
STATEMENT OF BASIS
This decision is based upon the administrative record for the Compass Industries
Superfund Site [index attached]. The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The major components of the selected remedy include:
! Installation of a cover which isolates contaminated material from human contact and
reduces infiltration or precipitation through the landfill area. The capping and closure
procedures will be designed in accordance with the Resource Conservation and
Recovery Act (RCRA) to achieve a goal of 10-7 cm/sec premeability. If a synthetic liner
is determined to be technically feasible and cost effective in accordance with the
preliminary cost estimates developed in the Feasibility Study, that liner shall be no
thicker than 30-40 mil.
! Collection and on-site treatment of contaminated groundwater in the upper, perched
water bearing zone, if deemed necessary through compliance monitoring following
installation of the cover material.
! Installation of fences and signs along the perimeter of the cap.
DECLARATION
The selected remedy is protective of human health and the environment, attains Federal
and State requirements that are applicable or relevant and appropriate and is
cost-effective. Finally it is determined that this remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable.
Compass Industries Landfill
Record of Decision Concurrences
The Compass Industries Landfill Record of Decision has been reviewed and I
concur:
TABLE OF CONTENTS
PAGE
I. SITE LOCATION AND DESCRIPTION
Site History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Remedial Investigation Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Potential Impact of Site on Human
Health and the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
II. ENFORCEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
III. COMMUNITY RELATIONS HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
IV. ALTERNATIVES EVALUATION
Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Description of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Evaluation of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
V. PROPOSED REMEDY
Rationale . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Consistency with the National Contingency Plan
and Superfund Statutes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Operation and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Future Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
VI. APPENDICES
A. Tables 1-4
B. Community Relations Responsiveness Summary
C. Agency for Toxic Substances and Disease Registry (ATSDR)/Centers for Disease
Control (CDC) Evaluation
D. Administrative Record Index
E. State Concurrence Letter
EXECUTIVE SUMMARY
The Compass Industries site is an abandoned landfill located west of Tulsa, Oklahoma.
The site occupies an abandoned limestone quarry. From 1972 to 1976 the site was
permitted and operated as a solid and industrial waste landfill.
Geologic investigations verify that the site is underlain by two aquifers. The Hogshooter
Formation contains a shallow aquifer and the Layton Sandstone member of the Coffeyville
Formation forms a deeper aquifer. The Hogshooter Formation forms an unconfined,
low-yield perched aquifer. Between the upper and lower aquifers is a sequence of 32 to 50
feet of shales. The relatively low permeability of these shale units acts as a partial confining
bed that restricts the downward migration of groundwater. Therefore, most of the
groundwater contamination is confined to the Hogshooter Formation and the overlying
soils.
Summary of Remedial Alternatives Selection for
Compass Industries Landfill
Tulsa County, Oklahoma
July 1987
I. SITE LOCATION AND DESCRIPTION
The Compass Industries site is an abandoned landfill located in a former limestone
quarry west of Tulsa, Oklahoma (Figure 1). It is situated directly west of the Chandler
Park softball facility, which is owned and maintained by Tulsa County. Physically, the
site is situated on a bluff approximately one-quarter mile south and 200 feet above the
Arkansas River. The site's topography slopes downward to the west and north and
ranges in elevation from approximately 770 to 860 feet above mean sea level. The
majority of runoff flows through water gaps in the ridge between the landfilled area and
the river or to ponds on the landfill. The clayey topsoil that is present is derived from
cover material utilized by the landfill operation. The natural soils in the area are
composed mainly of limestone residuum and similar constituents. Pioneer plant
species and grasses cover most of the site.
Site History
The Compass Industries site is located in a former limestone quarry which operated
from the 1930's through the 1950's. The site was permitted by the Oklahoma State
Department of Health and operated as a landfill from 1972 to 1976. There is evidence
that dumping occurred as early as 1964. As one of the major landfills in the Tulsa area
during those years, it accepted both municipal and industrial wastes. Unlike most
landfills in current operation, the operators of Compass Industries landfill apparently
kept few records concerning which wastes were disposed in the landfill. In addition, site
data indicates that disposal of the waste was done in an irregular manner, making it
difficult to ascertain where the wastes are located.
During the 1970's, several fires were reported at the landfill. The most recent fire
burned out in late 1984. It had burned underground for several years, breaking through
the topsoil cover on occasion. During this same time period, citizen complaints of
odors prompted air monitoring in the vicinity of the landfill. The results obtained from
this monitoring revealed the presence of some organics, but at levels that were
considered non-hazardous. Currently there are no known underground fires at the site;
however, there exits a potential for future fires.
The Compass Industries site was listed on the National Priorities List (NPL) in
September 1984, and funding for the remedial investigation and feasibility study was
provided by the U. S. Environmental Protection Agency (EPA).
3
Geology
The Compass Industries site occupies an abandoned limestone quarry on a hilltop about
200 feet above the Arkansas River, and 1/4 mile south of the site on the north. Surface
water from precipitation runoff, springs, and seeps flows into the Arkansas River through a
simple network of small streams.
The Hogshooter Formation and the Coffeyville Formation outcrop in and around the site
(Figure 2), and comprise part of a sequence of shales, sandstones, and limestones
formed in shallow marine and deltaic environments in late Pennsylvanian time.
The Hogshooter Formation forms an unconfined, low-yield perched aquifer that is exposed
at the surface on all sides of the site. This aquifer is recharged directly from local
precipitation infiltration and is discharged through seeps and springs into surface waters
near and within the site.
A thick sandstone zone, the Layton Sandstone member of the Coffeyville Formation, forms
a second, somewhat deeper aquifer. It too recharges from precipitation and discharges
through seeps to surface water. No use of water from either of these aquifers is known.
Water table contour maps of each aquifer indicate that groundwater flows to the
west-northwest at the site.
The volume of the waste was determined to be approximately 620,000 cubic yards. The
average groundwater flow rate of both aquifers is 720 gallons per day or an estimated
263,000 gallons of water per year.
Remedial Investigation Results
During the RI of the Compass Industries site, samples were collected from soil, water, and
air to determine if significant pollutant concentrations are present. Routes of off-site
migration include surface runoff, groundwater (by way of recharge to seeps and surface
runoff), transported sediments, and air.
Analytical results of the samples collected from the site indicate a large number of organic
and inorganic priority pollutants were detected. They include a total of 12 inorganic priority
pollutants and at least 33 organic priority pollutants, the most common priority pollutants
being base-neutral compounds. The concentrations were greatest in samples of waste
collected from the surface and in test trenches.
Groundwater samples were collected from 19 monitoring wells during the RI. These include
18 samples collected from 14 shallow wells completed in the perched water table aquifer,
and eight samples collected from five deep wells completed in the Layton Sandstone.
5
Surface water runoff and sediment samples from drainageways were collected around the
perimeter of the landfill to determine if contaminated runoff and sediments were leaving the
site. Sampling sites for surface water runoff were selected following several on-site
inspections during rainfall events. The general direction of surface runoff is to the north and
northwest. Sites for sediment sampling were located using aerial photographs,
topographic maps, and on-site field surveys. Seven sediment samples from seven
locations were collected, generally in the same areas where runoff samples were
collected.
Ten seep samples were collected to determine if contaminants were being leached out of
the landfill wastes and transported. Seepage occurs along the perimeter of the landfill near
the contact between the Hogshooter Formation and Coffeyville Formation. Sampling sites
were located following a period of wet weather by observing potential seep areas
identified during the preceding winter. Freezing conditions during the winter permitted the
identification of seeps as ice was formed at the point of discharge from the bluffs.
Surficial soil samples were collected randomly around the perimeter and within the interior
of the site to determine if surficial soils were contaminated. Eleven soil samples were
collected at the 11 locations. One sample was collected near the site entrance as a
background sample for comparing constituent concentrations.
In order to determine the extent, characteristics, and distribution of the waste at the site,
samples were also collected from the bottom of 17 backhoe trenches.
Air samples were collected by the EPA Technical Assistance Team (TAT) during trench
excavation and waste sampling. These samples were collected immediately upwind,
downwind, and within the test pit. In addition, air monitoring using an organic vapor
analyzer (OVA) was performed at each trench during excavation.
Conclusions
The hydrogeologic and topographic setting of the Compass Industries site appears to
minimize the migration of contaminated groundwater both laterally and vertically. The site
is located on a bluff a short distance above the Arkansas River. Both the shallow and deep
aquifers (the Hogshooter Formation and Layton Sandstone member of the Coffeyville
Formation, respectively) outcrop around the entire perimeter of the site. The deep aquifer
is separated from the shallow aquifer by 35 to 50 feet of shale units. The relatively low
permeability of the shale acts as a partial confining bed that appears to restrict most of the
downward migration of contamination to the deep aquifer. Therefore, it appears that most
of the contaminated groundwater at the site is contained within the Hogshooter Formation
and overlying soils.
6
An evaluation of all sample results presented in the Remedial Investigation Report for the
Compass Industries site has resulted in the following interpretations on the extent and
concentration of hazardous wastes at the site.
1. Migration of contaminants in the groundwater is currently being mitigated by attenuating
mechanisms since much greater concentrations were measured in solid samples.
Possible attenuating mechanisms include compounds with relatively low solubility and
miscibility and high soil adsorption capacities.
2. Table 1 provides a list of the three highest concentrations of inorganic and organic
priority pollutant compound concentrations for samples of groundwater and waste. This
table shows that greater contaminant concentrations are present in the wastes than in
groundwater and that the deep groundwater is less contaminated than the shallow
groundwater. The highest concentrations of organic compounds for aqueous samples
were detected in the sample from USEPA/TAT well number one. This sample is
probably of an isolated zone of disposed liquid wastes.
3. Off-site contaminant migration is currently limited to surface runoff and seeps (which
are fed by groundwater). Currently this does not present a significant health threat.
4. Samples of groundwater from monitoring wells on the site is highly contaminated. This
indicates a degradation of groundwater quality die to waste disposal in both the
perched and deep aquifers. The perched aquifer is much more severely contaminated
than the deep aquifer.
5. Where wastes were sampled at the ground surface many samples contained
significant concentrations of both inorganic and organic priority pollutants. The surface
waste samples were similar in composition to wastes sampled from trenches.
6. The site's impact on air quality appears to be minimal at this time and it is only during
intrusive activities, such as trenching or during fires, that elevated levels of air
contaminants may present a health hazard.
7. The volume of the waste was determined to be approximately 620,000 cubic yards.
The average groundwater flow rate of both aquifers is 720 gallons per day.
Groundwater remediation will require treatment of an estimated 263,000 gallons of
water per year.
7
Potential Impact of Site on Human Health and the Environment
The three major pathways of possible off-site contaminant migration are surface water,
groundwater, and air. The possibility also exits for direct contact at the site with
contaminated source materials, such as sludge, soil, or sediments.
Surface water runoff and seeps that discharge along the perimeter of the site are the most
significant pathways of contaminant migration off-site. Exposure to surface water can be
by direct contact or by ingestion. The transfer of contaminants to off-site surface water is
another possible exposure pathway.
The majority of the contamination in the groundwater is confined to the upper aquifer.
Relatively impermeable shales between the upper and lower aquifers serve to reduce the
flow of contaminants to the lower aquifer. Significant concentrations of organic and
inorganic contaminants were detected in the shallow aquifer. A detailed analysis of the
contaminants detected is contained in the RI report.
The site contains a significant concentration of relatively low hazard gases, and exhibits
only trace quantities of toxic volatile organic vapors. A minimal respiratory hazard is posed
by the site, although a potential hazard may exist in the event of a subsurface disturbance
or fire. Exposure due to air emissions can be by inhalation or indirect contact. The source
material poses an exposure risk due to direct contact or by inhalation and ingestion of
airborne dust.
II. ENFORCEMENT
Approximately 20 Potentially Responsible Parties (PRPs) have been identified, and may
be given special notice to conduct the Remedial Design and Action. To date, there has
been no PRP involvement at the site.
III. COMMUNITY RELATIONS HISTORY
Several fires were reported in the landfill during the 1970's. The most recent fire burned for
several years before it apparently burned out in 1984. Air monitoring was conducted at the
site in response to citizen complaints of strong odors coming from the landfill. The results
obtained from the air monitoring showed the presence of organics, but at non-hazardous
levels. Investigations conducted by the Environmental Protection Agency (EPA) led to the
sites inclusion on the National Priorities List in September 1984.
On July 25, 1984, the U.S. Environmental Protection Agency (EPA) issued a news release
announcing that funds had been awarded to the Oklahoma State Department of Health
(OSDH). That money was used to conduct studies at the Compass Industries site.
8
The OSDH held a public meeting at the Berryhill High School on August 20, 1984, to
explain the project, answer questions, and take comments.
The completion of the studies was announced to the public via news releases issued by
the OSDH on July 16, 1987, and the EPA on July 22, 1987. The scheduling of the August
18, 1987, public meeting to discuss the proposed remedy for the site was also announced.
An EPA prepared fact sheet which described alternative cleanup plans along with the EPA
preferred alternative was sent to the interested and affected public on July 22, 1987. The
fact sheet gave a brief site history, described the process and alternatives and gave
details about the public comment period and public meeting.
Because of the increase in public interest the public meeting on August 18 was changed from
the original public library location to the Berryhill School auditorium so that enough seating
was assured. The change of location was announced in an EPA news release issued August
7, 1987.
Approximately 65 people attended the August 18, 1987, public meeting.
Community concerns centered around costs of the alternative remedies, efficiency and
public health.
Further details concerning Community relations are contained in Appendix C.
IV. ALTERNATIVES EVALUATION
Evaluation Criteria
Section 121(b),(1)(A-G) of the Superfund Amendments and Reauthorization Act contains
the nine factors which EPA must consider in selecting a remedy for a Superfund site.
These are summarized below:
1. Consistency with Other Environmental Laws
In determining appropriate remedial actions at Superfund sites, consideration
must be given to the requirements of other Federal and State environmental
laws, in addition to CERCLA as amended by SARA. Primary consideration is
given to attaining applicable or relevant and appropriate Federal and State
public health and environmental regulations and standards. Not all Federal and
State environmental laws and regulations are applicable to each Superfund
response action. The compliance of each remedial alternative with all applicable
and relevant environmental laws is shown in Table 2.
2. Reduction of Toxicity, Mobility or Volume
The degree to which alternatives employ treatment that reduces toxicity,
mobility, or volume must also be assessed. Relevant factors are:
9
! The treatment processes the remedies employ and materials they will treat;
! The amount of hazardous materials that will be destroyed or treated;
! the degree of expected reduction in toxicity, mobility, or volume;
! The degree to which the treatment is irreversible;
! The residuals that will remain following treatment, considering the
persistence, toxicity, mobility, and propensity for bioaccumulation of such
hazardous substances and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of alternatives must be assessed considering
appropriate factors among the following:
! Magnitude of reduction of existing risks;
! Short-term risks that might be posed to the community, workers, or the
environment during implementation of an alternative including potential
threats to human health and the environment associated with excavation,
transportation, and redisposal or containment;
! Time until full protection is achieved.
4. Long-term Effectiveness and Permanence
Alternatives are assessed for the long-term effectiveness and permanence they
afford along with the degree of certainty that the remedy will prove successful.
Factors considered are:
! Magnitude of residual risks in terms of amounts and concentrations of waste
remaining following implementation of a remedial action, considering the
persistence, toxicity, mobility, and propensity for bioaccumulation of such
hazardous substances and their constituents;
! Type and degree of long-term management required, including monitoring
and operation and maintenance;
! Potential for exposure of human and environmental receptors to remaining
waste considering the potential threat to human health and the environment
associated with excavation, transportation, redisposal, or containment;
10
! Long-term reliability of the engineering and institutional controls, including
uncertainties associated with land disposal of untreated wastes and
residuals;
! Potential need for replacement of the remedy.
5. Implementability
The ease or difficulty of implementing the alternatives are assessed by
considering the following types of factors:
! Degree of difficulty associated with constructing the technology;
! Expected operational reliability of the technologies;
! Need to coordinate with and obtain necessary approvals and permits (e.g.,
NPDES, Dredge and Fill Permits for off-site actions) from other offices and
agencies;
! Availability of necessary equipment and specialists;
! Available capacity and location of needed treatment, storage, and disposal
services.
6. Cost
The types of costs that should be assessed include the following:
! Capital cost;
! Operation and maintenance costs;
! Net present value of capital and O & M costs;
! Potential future remedial action costs.
7. Community Acceptance
This assessment examines:
! Components of the alternatives that the community supports;
! Features of the alternatives about which the community has reservations;
! Elements of the alternatives which the community strongly opposes.
11
8. State Acceptance
Evaluation factors include assessments of:
! Components of the alternatives the State supports;
! Features of the alternatives about which the State has reservations;
! Elements of the alternatives under consideration that the State strongly
opposes.
9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against individual evaluation
criteria, the alternatives are assessed from the standpoint of whether they
provide adequate protection of human health and the environment considering
the multiple criteria.
EPA is also directed by SARA to give preference to remedial actions that utilize
treatment to remove contaminants from the environment. Offsite transport and
disposal without treatment is the least preferred option where practicable
treatment technologies are available.
Description of Alternatives
In conformance with the National Contingency Plan, an initial set of remedial approaches
were screened to determine whether they might be appropriate for this site. (See the
Feasibility Study for details of this evaluation). From these possible remedies, six
alternatives were chosen for more detailed evaluation and comparison with the remedy
selection criteria outlined above. Each is summarized below:
ALTERNATIVE 1, NO-ACTION - This remedy, consists primarily of restricting public
access to the contaminated areas and monitoring the site. The area will be fenced
and warning signs will be installed. Site monitoring will involve periodic air and
groundwater sampling and analysis. The estimated cost to implement the no action
alternative is $672,000.
Four of the remedial action alternatives include a cap which meets RCRA specifications.
The RCRA specification cap will isolate the contaminated source material from potential
public and wildlife contact and will significantly reduce the infiltration of precipitation
through the landfiIled area. Surface water diversion technologies will also be implemented
to reduce flow over the surface and to reduce the potential for infiltration. The cap will be
graded to encourage site run-off and simultaneously prevent erosion of the soil and
vegetative cover. The cap design includes gas collection and atmospheric venting, which
will be monitored up-gradient and down-gradient of the site in both the
12
shallow and deep aquifers. Groundwater that emerges from the downgradient hillside to
become surface water will also be monitored. Fences and signs will be placed along the
perimeter of the site to protect the cap from disturbances.
ALTERNATIVE 2, CAP AND ON-SITE GROUNDWATER TREATMENT - This
alternative, is comprised of site grading, cap placement, diversion of surface water,
groundwater collection and treatment, and air emissions monitoring. The grading,
cap design, gas venting, and surface water diversion technologies were presented
in the previous paragraph. Groundwater will be collected prior to its emergence
from the down-gradient hillside. The contaminated groundwater will be collected,
combined, and treated to State and Federal standards prior to discharge to the
Arkansas River. A filtration unit will be specified such that effluent solids levels meet
National Pollution Discharge Elimination System (NPDES) requirements. The
precipitated metals and other solids from the separation unit will be dewatered. For
purposes of cost estimation it is anticipated that the solids will be processed in a
mechanical filter unit and disposed as a hazardous solid waste material in a
permitted, off-site landfill if the material meets the criteria for land disposal. The
estimated cost of the cap and on-site groundwater treatment alternative is $12
million.
ALTERNATIVE 3, CAP AND OFF-SITE GROUNDWATER TREATMENT
ALTERNATIVE - This remedy is similar to Alternative 2 except that the groundwater
will be collected and transported to an off-site treatment facility. It is anticipated that
the groundwater will be placed into a 10,000-gallon holding tank. Groundwater will
be routinely transported for off-site treatment and disposal. The estimated cost of
the cap and off-site groundwater treatment alternative is $13 million.
ALTERNATIVE 4, FULL ON-SITE THERMAL DESTRUCTION ALTERNATIVE -
Involves removing all landfilled material and destroying it in an on-site thermal
destruction unit for destruction or removal of 99.99 percent of the organics.
Materials handling will include hauling hazardous waste materials, contaminated
soils and sediments, and the non-hazardous landfill material to the on-site thermal
treatment unit. Upon thermal destruction, the released volatile gases will be
collected and burned at a higher temperature and the stack gases will be scrubbed
and treated prior to atmospheric release. The residual ash will be tested, solidified
if necessary, and disposed of in an appropriate manner dependent upon
performance of the toxicity characteristic leaching procedure (TCLP) and other
relevant tests. The groundwater will be collected and treated similar to Alternative 2.
Performance specifications for treatment would be developed during remedial
design from information obtained during RI and would be the basis for the level of
thermal destruction. The performance specifications would address pretreatment
requirements, materials handling, testing, and disposal options. The estimated cost
of the full on-site incineration alternative is $339 million.
13
ALTERNATIVE 5, PARTIAL ON-SITE THERMAL DESTRUCTION AND CAP -
Consists of excavating and thermally destroying the source areas of contaminated
material, capping the entire site, installing barriers, and collecting and treating the
contaminated groundwater. Residual ash will be solidified if necessary, and
disposed of in an on-site landfill which meets RCRA specifications or in an
appropriate manner following performance of the TCLP and other relevant tests.
The estimated cost of the partial on-site thermal destruction alternative is $17
million.
ALTERNATIVE 6, PARTIAL OFF-SITE THERMAL DESTRUCTION AND CAP -
This alternative is similar to Alternative 5 except treatment of contaminated wastes
and groundwater will be performed off-site on a service basis. The hazardous
material will be removed and transported to the off-site thermal treatment unit,
sized, and destroyed. Residual ash will be solidified, if necessary, and disposed of
in an off-site landfill which meets RCRA specification or in an appropriate manner
following performance of the TCLP and other relevant tests. The estimated cost of
the partial off-site thermal destruction alternative is $45 million.
Evaluation of Alternatives
The degree that the six remedial alternatives meet the nine selection criteria is contained
in Table 3. The following values were assigned to compare remedial selection criteria:
++ Alternative would greatly exceed a selection criterion when compared to other
alternatives.
+ Alternative would exceed a criterion in comparison to other alternatives.
0 Alternative can be designed to meet the selection criterion.
- Special efforts will be necessary in the design of the remedy to meet the selection
criterion.
-- In comparison to other remedies, these alternatives would present most difficulty in
achieving a selection criterion.
The rationale for the ratings assigned in this table is as follows:
1. COMPLIES WITH ARARs (i.e., meets or exceeds applicable or relevant and
appropriate Federal and State requirements)
Incineration was rated the highest for this criterion (++) because in addition to
exceeding all environmental rules, this alternative most effectively meets the preference
in SARA for destruction of contaminants. All other alternatives, except for the no action
alternative, received a rating of “+” because they all can be designed
14
to exceed applicable standards. The no action remedy was rated”--“ because it does
not meet the intent of the RCRA and Superfund requirements for remediation of a
hazardous waste site. The National Contingency Plan provisions to respond to a threat
of release are also violated by this remedy.
2. REDUCES MOB., TOX., VOL. (i.e., Reduces the Mobility, Toxicity, or Volume of
Waste)
a. No Action was rated "--" because it does nothing to reduce any of these
parameters.
b. Cap and On-site Groundwater Treatment and Cap and Off-site Groundwater
Treatment (Alternatives 2 and 3) - Both of these alternatives were judged to
effectively reduce the mobility of contaminants. The groundwater treatment serves
to reduce the volume and toxicity of wastes on site to some degree and were
therefore rated "0".
c. Full On-site Thermal Destruction was rated "++" for each parameter because this
process would destroy the organic compounds in the waste.
d. Partial On-site Thermal Destruction, Cap, and Groundwater Treatment and Partial
Off-site Thermal Destruction, Cap, and Groundwater Treatment (Alternatives 5 and
6) - Because these two remedies would reduce the mobility of wastes only slightly
better than Alternatives 2 and 3, they were assessed to be essentially equivalent
and were rated "+". The partial destruction of wastes does result in reductions in
toxicity (meriting a single +) and a small reduction in volume (a rating of 0) when
compared to the simple cap and groundwater treatment remedies.
3. SHORT TERM EFFECTIVENESS
The simple capping remedies (alternatives 2 and 3) were judged capable of being
designed to present essentially no risks to workers or residents. The on-site thermal
treatment options were assigned a single "-" because these risks can be prevented but
would require attention in the design. The added risks of transporting untreated waste
long distances resulted in off-site thermal treatment receiving a “--" rating. Doing
nothing leaves contaminated seeps and waste exposed to the public, thus no action
rated
4. LONG TERM EFFECTIVENESS
All alternatives, except no action, will successfully reduce long term risks to human
health and the environment. Because of the added assurance from the destruction of
the organic waste, the full incineration was rated "++".
15
5. IMPLEMENTABILITY
Onsite incineration remedies (alternatives 4 and 5) will require relatively more attention
during design than other remedies to ensure implementability and were therefore rated
lower ("-") than the other alternatives.
6. COST
Estimated costs for each alternative are summarized in Table 4. Included in this table
are total capital and implementation costs, annual operation and maintenance costs,
total present worth, and replacement costs. Replacement costs were included to
evaluate the cost of remedial action if the alternative were to fail. A replacement cost of
$5 million was assessed for the cap and on-site groundwater treatment alternative and
the cap and off-site groundwater treatment alternative. This replacement cost is an
estimate of replacement of the cap.
The no action alternative had the lowest present worth and operation and maintenance
costs. The cap and on-site groundwater treatment and the cap and off-site groundwater
treatment alternatives were the next least expensive, with costs of $12 million to $13
million.
Most of the added costs for the remedy involving off-site groundwater treatment are
due to added transportation expenses. The partial on-site and partial off-site thermal
treatment remedies have a present worth of $17 million and $45 million respectively.
The increased cost of the partial off-site thermal destruction, cap, and groundwater
treatment alternatives is due to transportation expenses and the higher prices vendors
charge at permitted off-site thermal treatment facilities. The full on-site thermal
destruction and groundwater treatment alternative has an estimated present worth of
$339 million. This alternatives excessive cost over the partial thermal treatment
remedies is due to the increased volume of waste to be treated. Only 2 percent of the
waste will be treated with the partial thermal treatment remedies.
7. COMMUNITY ACCEPTANCE
At the public meeting on August 18, 1987, the public had several comments and
concerns pertaining to all of the remedies. Questions ranged from the damage the
remedies will cause to the environment to the time required for cleanup of the site. The
no action alternative was left blank because it was not discussed by the public. The
remedies involving a cap and groundwater treatment were rated "+" because the public
was in favor of this action over thermal treatment of the waste. A rating of "-" was given
to the alternatives involving thermal destruction because of the public concern that the
thermal treatment unit would create hazardous emissions and increase the potential for
exposure.
16
8. STATE ACCEPTANCE
A rating of "0" was given to the cap and on-site groundwater treatment remedy as
proposed in the Feasibility Study. The State (i.e., the Oklahoma State Department of
Health) has concurred with the capping portion of this remedy. The final decision for
this site defers treatment of groundwater. A rating of "-" was given to all other
alternatives because the State did not support any of the other proposed remedies.
9. Overall Protection of Human Health and the Environment
Full on-site thermal destruction received the highest rate of “++” because it results in
elimination of the organic contaminants. The thermal treatment unit would be designed
to meet RCRA standards. The possibility exists that noxious odors will be given off
during the treatment process, but a contingency plan will be developed to address this
problem. Destruction of 99.99% of the organic contamination will reduce the potential
for human exposure.
The remaining alternatives, except for the no action alternative, were rated "+". This
rating is due to the health threat posed by untreated waste remaining on-site. The no
action alternative received a rating of "--" for the same reason. This remedy provides
no reduction in exposure pathways.
V. PROPOSED REMEDY: RCRA CAP
Rationale
Considering the current and potential site hazards, and also taking into account the unique
hydrology of the area, the recommended remedy is a RCRA cap. This alternative consists
of site grading, cap placement, diversion of surface water, and air emissions monitoring.
The site cap will be required to meet RCRA specifications. Groundwater will be treated at
a later date if found to be necessary. This alternative will also require installation of security
fences and signs to restrict access to the site.
The site will be monitored for a period of at least 30 years (post-closure time period
stipulated under RCRA) to ensure that no significant contaminant concentrations migrate
from the site. If however, future migration does occur appropriate remedial actions will be
taken.
This alternative is protective and cost-effective, attains applicable or relevant and
appropriate Federal and State standards, and utilizes
17
permanent solutions and treatment technologies to the maximum extent practicable. The
reasons for elimination of the other remedies are as follows:
Alternative No. 1; No-action; this alternative is not protective of public health and the
environment. It does not meet the intent of RCRA or SARA.
Alternative No. 3; Cap and off-site groundwater treatment; this alternative is the same as
alternative 2 except that it entails off-site groundwater treatment. This
remedy meets the requirements listed in RCRA, however it is relatively
more costly. The potential for human exposure would be increased due
to off-site transport of contaminants.
Alternative No. 4; Full on-site thermal destruction; complies with RCRA regulations and
also meets many of the preferences listed in SARA. However, this
remedy is not cost-effective ($339 million vs. $12 million).
Alternative 2 provides a safe solution to the hazardous waste problem
which allows that the waste be left on-site. It also takes advantage of
the site's unique hydrology and a RCRA cap to halt migration and
further contamination of the groundwater. For this reason, it can be
assumed that alternative 2 is protective to human health and the
environment.
Alternative No. 5; Partial on-site thermal destruction and cap; this alternative is also not
cost effective ($17 million vs $12 million). Under this proposal only one
percent or so of wastes would be destroyed yielding negligible
environmental benefits. As just stated, the increase in cost does not
justify the negligable increase in protection to human health and the
environment.
Alternative No. 6; Partial off-site thermal destruction and cap; this alternative meets the
requirements of RCRA and SARA. The potential for human exposure
would be increased due to off-site transportation. The minor increase in
protection to human health and the environment does not justify an
increased cost of $45 million.
Consistency with the National Contingency Plan (NCP) and the Provisions of the
Superfund Amendments and Reauthorization Act of 1986 (SARA)
The proposed remedy provides adequate protection of public health, welfare, and the
environment. This alternative is also consistent with the National Contingency Plan (NCP),
in 40 CFR 300.68(h)(2)(iv) and (vi) (Federal Register, 1985) which requires:
18
(iv) An assessment of each alternative in terms of the extent to which it is expected to
effectively mitigate and minimize threats to and provide adequate protection of public
health, welfare and the environment.
(vi) An analysis of any adverse environmental impacts, methods for mitigating these
impacts, and costs of mitigation.
Additionally, the long-term effectiveness factors cited in SARA Section §121(b)(1) were
addressed. These include:
A) The long-term uncertainties associated with land disposal;
B) The goals, objectives, and requirements of the Solid Waste Disposal Act;
C) The persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents.
D) Short- and long-term potential for adverse health effects from human exposure;
E) Long-term maintenance cost;
F) The potential for future remedial action costs if the remedial action in question were to
fail; and
G) The potential threat to human health and the environment associated with excavation,
transportation, and redisposal, or containment.
Operation and Maintenance (O&M)
Site operation and maintenance will include a groundwater and air monitoring and analysis
program, inspection of the surface vegetatIon, and the periodic repair of the perimeter
fence. Cap maintenance will entail the inspection of the cap and the maintaining and
replacing of the passive gas filters associated with the gas collection and venting system.
The State of Oklahoma will have the responsibility for O&M for a period of a least 30 years
after completion of the remedial action.
Future Actions
No future remedial actions are anticipated. The selected remedial action is considered
permanent. If, however, significant unforeseen off-site contamination occurs as a result of
the site, appropriate remedial measures will be taken. As stated under the O&M section,
the site will be monitored for a least 30 years to ensure the reliability of the implemented
remedial action.
SARA also states that if an alternative results in any hazardous substances, pollutants, or
contaminants remaining onsite, the remedy will be reviewed at least every five years to
assure that human health and the environment are being protected.
19
Remedial Action Schedule
Approve Remedial Action (sign ROD) September 1987
Complete Enforcement Negotiations January 1988
Obligate Funds to Begin Remedial Design January 1988
(assuming the PRPs do not take over)
Complete Design March 1989
Obligate Funds to Start Remedial Action March 1989
Complete Remediation September 1990
APPENDIX A
Table 1
COMPOUNDS HAVING HIGHEST CONCENTRATIONS IN
SAMPLES OF GROUNDWATER
Shallow Well
(ug/L)
Deep Well
(ug/L)
Inorganic Compounds Inorganic Compounds
zinc* 7497 barium 1450
lead* 3397 zinc* 1128
copper* 3162 chromium* 353
Organic Compounds Organic Compounds
2-methynaphthalene 98000 bis(2-ethylhexyl)
phenenthrene* 62000 phthalate* 30
bis(2-ethylhexyl)*
phthalate 46000
toluene*
di-n-butyl
phthalate*
6
0.8
COMPOUNDS HAVING HIGHEST CONCENTRATIONS
IN SAMPLES OF WASTE
Trenches
(mg/kg)
Surface Waste
(mg/kg)
Inorganic Compounds Inorganic Compounds
zinc* 2132 copper* 19930
chromium* 1639 zinc* 5450
lead* 1555 lead* 2790
Organic Compounds Organic Compounds
2 methylnaphthalene 5300 benzo (b)
phenenthrene* 250 fluoranthene* 1600
xylenes 190 benzo (a)
anthracene* 1100
pyrene* 710
* Priority pollutants
NOTE: Units equivalent to parts per million.
Does not include methylene chloride, a suspected lab
contaminant. Tentatively identified compounds (e.g.,
hydrocarbons) not included.
TABLE 2
TABLE OF REMEDIAL ALTERNATIVES COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL LAWS AND REGULATIONS
LAW OR REGULATION ANALYSIS
NO
ACTION
CAP AND
ON-SITE
GROUNDWATER
TREATMENT
CAP AND
OFF-SITE
GROUNDWATER
TREATMENT
FULL
ON-SITE
THERMAL
DESTRUCTION
PARTIAL
ON-SITE
THERMAL
DESTRUCTION
AND CAP
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
AND CAP
Federal
Resource Conservation
and Recovery Act
(RCRA)
Violations
likely
X
Compliance
demonstrated
or feasible
X X X X X
DOT Hazardous
Material Transport
Rules
Not
Applicable
X X X X
Compliance
demonstrated
or feasible
X X
Clean Air Act (CAA)
and National
Ambient Air Quality
Standards (NAAQS)
Not Applicable
Compliance
demonstrated
or feasible
X X X
X X X
Toxic Substances
Control Act (TSCA)
Not
Applicable
X X X X X X
National Pollutant
Discharge
Elimination System
(NPDES)
Requirements
Not
Applicable
Compliance
demonstrated
or feasible
X
X
X X X X
TABLE 2 (continued)
TABLE OF REMEDIAL ALTERNATIVES COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL LAWS AND REGULATIONS
LAW OR REGULATION ANALYSIS
NO
ACTION
CAP AND
ON-SITE
GROUNDWATER
TREATMENT
CAP AND
OFF-SITE
GROUNDWATER
TREATMENT
FULL
ON-SITE
THERMAL
DESTRUCTION
PARTIAL
ON-SITE
THERMAL
DESTRUCTION
AND CAP
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
AND CAP
Clean Water Act Violations
likely
X
Compliance
demonstrated
or feasible
X X X X X
Executive Orders
(EO) for Food
Plain (11988)
Not Applicable X X X X X X
Fish and Wildlife
Coordination Act
(FWCA)
Applicable X X X X X X
Endangerment Species
Act
Applicable X X X X X X
State
Oklahoma Solid Waste
Regulations
Not
Applicable
X X X
Compliance
demonstrated
or feasible
X X X
TABLE 2 (continued)
TABLE OF REMEDIAL ALTERNATIVES COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL LAWS AND REGULATIONS
LAW OR REGULATION ANALYSIS
NO
ACTION
CAP AND
ON-SITE
GROUNDWATER
TREATMENT
CAP AND
OFF-SITE
GROUNDWATER
TREATMENT
FULL
ON-SITE
THERMAL
DESTRUCTION
PARTIAL
ON-SITE
THERMAL
DESTRUCTION
AND CAP
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
AND CAP
Oklahoma Hazardous
Waste Regulations
Not Applicable X X x x
Compliance
demonstrated
or feasible
X x
Oklahoma Clean Air
Act (CAA)
Violations
likely
X
Compliance
demonstrated
or feasible
X X X X X
Oklahoma Water
Quality Standard
Violations
likely
X
Compliance
demonstrated
or feasible
x x x x x
Local
Local Permits Not
Applicable
x x x x x x
TABLE 3
COMPARISON OR REMEDIAL ALTERNATIVES
COMPASS INDUSTRIES
SUPERFUND SITE
ALTERNATIVES
COMPLIES
WITH
ARARS
REDUCES
SHORT
TERM
EFFECT
LONG
TERM
EFFECT
IMPLEMENT-ABILITY
COST
$ MILLION
INIT. REPL.
COMMUNITY
ACCEPT.
STATE
ACCEPT.
OVERALL
PROTECT
MOB. TOX. VOL. OF HH&E
1. NO ACTION - - - - - - - - - - - - + + 1 0 - - - -
2. CAP & ON-SITE
GW TREATMENT + + 0 0 0 + 0 12 5 + 0 +
3. CAP & OFF-SITE
GW TREATMENT + + 0 0 0 + 0 13 5 + - +
4. FULL ON-SITE
THERMAL
DESTRUCTION
GW TREATMENT
+ + + + + + + + - + + - 339 0 - - + +
5. PARTIAL ON-SITE
THERMAL
DESTRUCTION, CAP,
& GW TREATMENT
+ + + 0 - + - 17 0 - - +
6. PARTIAL OFF-SITE
THERMAL
DESTRUCTION, CAP,
& GW TREATMENT
+ + + 0 - - + - 45 0 - - +
TABLE 4
COST SUMMARY OF REMEDIAL ALTERNATIVES
ALT. 1
NO
ACTION
ALT. 2
CAP AND
ON-SITE GW
TREATMENT
ALT. 3
CAP AND
OFF-SITE GW
TREATMENT
ALT. 4
FULL ON-SITE
THERMAL
DESTRUCTION,
AND GW
TREATMENT
ALT. 5
PARTIAL
ON-SITE
THERMAL
DESTRUCTION,
CAP AND GW
TREATMENT
ALT. 6
PARTIAL
OFF-SITE
THERMAL
DESTRUCTION
CAP AND GW
TREATMENT
Total Capital &
Implementation
Cost ($)
374,638 9,255,526 9,288,548 336,806,813 14,676,999 41,446,622
Annual O&M
Cost ($)
31,590 272,830 360,280 254,430 272,830 360,280
Total Present
Worth ($)
672,435 11,827,271 12,684,877 339,205,303 17,248,944 44,842,951
Replacement
Cost ($)
0 5,000,000 5,000,000 0 0 0
APPENDIX B
Compass Industries Landfill Site
Tulsa, Oklahoma
Responsiveness Summary
This Community relations responsiveness summary is divided into two sections:
Section I: Background on Community Involvement and Concerns. This section
provides a brief history of community interest and concern raised during the
remedial planning activities on the Compass Industries Superfund site.
Section II: Summary of Major Comments Received during the Public Comment Period
and the EPA Responses to the Comments. Both written and spoken
comments are categorized by topics. EPA responses to these relevant
major topics are also presented.
I. Background on Community Involvement
The Compass Industries Landfill site is located in a sparsely populated area of west
Tulsa, Oklahoma. The community of Berryhill and the city of Sand Springs are within
two miles of the site. An elementary school lies within one-half mile and a major
regional park is immediately adjacent to the site.
Local residents and officials have long expressed concern regarding open burning
and other poor practices at the site. The smoke led citizens and local officials to
request studies to determine potential hazards at the site. The State began extensive
air and water sampling in 1983. EPA also performed sampling and no immediate
health hazards were identified.
The Berryhill Citizens for a Cleaner Environment, organized by residents reacting
primarily to smoke from the site, pressed for remedial action.
In May 1983 the site was evaluated as a possible candidate for inclusion on the
National Priorities List under the Superfund law. The Compass site was included on
the list in August 1983.
The preliminary investigation work began at the site in October 1983. The
underground fires stopped burning in October 1984.
On the afternoon of August 18, 1987, EPA staff members met with Tulsa City Officials
to brief them on the findings of the remedial investigation and feasibility studies, to
describe the various remedial alternatives considered, and to describe EPA's
preferred remedy.
2
Present were Major Dick Crawford; John Selph, Tulsa County Commissioner; Kieth
Francis representing Congressman Jim Inhofe; Sharon Keasler representing Senator
Don Nickles; Mike Wright and Jerry Cleveland of the Tulsa City-County Health
Department; R. Fenton Rood and Dennis Hrebec of the Oklahoma State Department
of Health; Patrick Boulder, Houston Adams, Louis Van Landingham, Priscilla Harris
and Herb Van Fleet of the City of Tulsa; Jennifer Kreel and Susan Young of INCOG;
and William Cox and Kenneth Hill of the City of Sand Springs.
Issues raised include costs of the various alternatives, efficiency of the EPA preferred
alternative and various technical questions.
At 7:00 pm on the evening of August 18, 1987, the public meeting began in the
Berryhill School Auditorium. Representatives of EPA and OSDH made presentations,
listened, and responded to public comments. Some 65 people attended.
II. Summary of Major Comments Received during the Public Comment Period and the
EPA Responses to the Comments
1. Comment: Will any drainage or erosion problems along Avery Drive be caused by the
remedial action at the Compass Industries site?
Response: No, Drainage and erosion issues will be addressed and provided for in
the design phase.
2. Comment: Can 32 acres be covered effectively by a synthetic liner?
Response: It is technically feasibility to cover 32 acres with a liner. Sites as large as
100 acres have been covered effectively with a synthetic liner. The engineering and
implementation of installing the liner will be addressed in the design phase.
3. Comment: Will the seeps going into the Arkansas River be treated?
Response: No, the seeps themselves will not be treated. The groundwater on-site
which generates the seeps may be treated in the future if necessary.
4. Comment: What quality standards will the treated water be required to meet?
Response: All State and Federal standards.
5. Comment: What volume of water will be treated?
Response: Treatment of groundwater is deferred pending an evaluation of the
effectiveness of the cap. The feasibility study estimates approximated a 263,000
gallon yield per year from the aquifers which discharge off-site. These estimates,
calculated over the 30-year operation and maintenance period amount to a total of
approximately 7,890,000 gallons.
3
Considering the majority of contaminants are within the upper zone of the aquifer
system, actual volume and timeframe for treatment should be considerably less.
6. Comment: If the landfill is capped, won't the water dry up eventually?
Response: In theory, the water in the perched or contained water bearing zone within
the landfill area should dry up. Treatment of the contaminated liquids, if found
necessary, in the landfill area will additionally reduce the potential for offsite migration
of contaminants.
7. Comment: Will the groundwater have to be airstripped? Will the resulting sludge be
landfilled on-site?
Response: Air stripping is a potential treatment alternative, however, a specific
technology is not specified in the Feasibility Study. If air stripping was selected
sludges could be landfilled on-site.
8. Comment: What protection will there be against air pollution?
Response: Construction of the cap remedy is not anticipated to generate any
uncontrollable adverse air emissions and will reduce the potential for future emissions.
9. Comment: How can the land be used if the cap and groundwater treatment remedy is
implemented?
Response: Future land use considerations will be evaluated in the upcoming design
phase based on the needs of protection of the cap.
10. Comment: How far along is EPA with identifying PRPs?
Response: Approximately 20 PRPs have been identified.
11. Comment: What is EPA's timetable for implementing a remedy at the site?
Response: Design, procurement of contractors and construction is estimated to take
approximately 3 years.
12. Comment: Why is there such a large difference in the the State recommended $1.6
million cap remedy and the EPA $13 million cap remedy.
Response: No basis for a $1.6 million cap remedy has been submitted by the State.
The construction cost estimates submitted as the official public comments by the
Oklahoma State Department of Health
4
(OSDH) for a the cap without liner is represented as costing $3,412,944. The States
proposed cap design is similar to the EPA RCRA cap design, less the synthetic liner.
The estimated construction costs of the EPA RCRA cap, with liner, is $4,256,000.
The balance of the $12 million cost estimate consists of groundwater collection and
treatment, contingency, implementation, and operation and maintenance costs.
Therefore the difference in costs is only $843,056. A more detailed cost comparison
is provided on page 11.
13. Comment: A liner would produce toxic fumes if the underground fires started again.
Response: By reducing oxygen within the landfill interior the synthetic liner will reduce
the potential for reoccurring underground fires. The possibility of the liner catching fire
is remote since it is contained within a 5' layer of compacted earthen material.
14. Comment: More engineering should be conducted prior to the selection of remedies.
Response: EPA disagrees with this viewpoint. Congress, through SARA, has
structured the Superfund program to-prevent the unnecessary expenditure of funds.
Detailed engineering information, necessary for the design stage, is not needed to
select a remedial concept.
15. Comment: The Compass Industries site should be considered an improperly closed
solid waste disposal facility and should be closed as required in the Oklahoma Solid
Waste Management Act.
Response: EPA disagrees. The Compass Industries site was permitted to accept
solid and hazardous wastes and was a major landfill in the Tulsa area. Documents
indicate in excess of 40,000 barrels of refinery sludges and waste liquids were
disposed of at the Compass Industries site. In addition, analytical data gathered
during the Remedial Investigation verifies the presence of hazardous waste on-site as
well as migrating off-site. Due to the presence of hazardous waste and the current
and potential migration of contaminants off-site the closure of the site in accordance
with Subtitle C of the Resource Conservation and Recovery Act, which requires a cap
with liner, is relevant and appropriate.
16. Comment: The low levels of compounds migrating off-site from the seeps establishes
a carcinogenic risk factor of 10-5 (1 in 100,000).
Response: The EPA goal is to reduce carcinogenic risk to 10-6 (1 in 1,000,000) for
groundwater.
5
17. Comment: The levels of compounds in the seeps do not cause a significant increase
of contaminants in the surface water of the Arkansas River.
Response: Levels of contaminants in the Arkansas river have no bearing on the
authority of EPA to respond to the release or threat of release of contaminants from
the Compass Industries site. The potential exists for direct contact with and ingestion
of the seeps themselves.
18. Comment: A cap without a liner can meet all applicable or relevant and appropriate
requirements.
Response: EPA agrees. However, if technically feasible a cap with a liner has
additional technical advantages and provides greater protection of public health and
the environment. A liner would be less permeable and would further reduce the
infiltration of surface water. The long term advantage to the liner is that less water
would be generated from the seeps.
19. Comment: Acute and chronic bioassays or multi series bioassays should have been
conducted as well as tests to determine bioaccumilation and bioconcentration of
toxics at the Compass Industries site.
Response: EPA disagrees. EPA typically relies on historical toxicological
information for evaluating contaminant levels at Superfund sites. The response
authority under CERCLA as amended by SARA extends beyond current effects from a
site to include potential releases (and effects) of contamination therefore biological
studies although informative, are not required for selecting a remedy.
20. Comment: No Endangerment Assessment on the Compass Industries site has been
available for review and no Health Assessment has been accomplished for the
Compass Industries site. Therefore no balancing of any such risks against the costs of
the remedies is possible.
Response: EPA disagrees. The information developed in the Endangerment
Assessment was in fact incorporated and utilized in the Feasibility Study and available
for public comment, although not under separate cover. Documents on which the
Record of Decision is based are included in the Administrative Record which is
available for public review prior to the signing of the Record of Decision. A Health
Assessment is not required prior to the signing of a Record of Decision. Adequate
data has been gathered with regards to potential health impacts on which to make a
selection of a remedy. The Agency for Toxic Substances and Disease Registry
(ATSDR) concurs with the EPA determination of the need to respond to the current
and potential release of contaminants from the site. ATSDR is currently evaluating the
information on the Compass Industries site and will provide a Health Assessment
which can be utilized during the upcoming design phase.
6
21. Comment: What long term impacts (20 to 30 years) does the site pose?
Response: The potential for future fires and continued off-site migration of
contaminants pose adverse human health and environmental impacts. Other impacts
which the site may pose cannot be effectively predicted. A RCRA cap and
groundwater treatment would mitigate these problems as well as most of the unseen,
long term problems.
22. Comment: Is there an approved Federal and/or State hazardous waste dump in the
State of Oklahoma?
Response: No, at this time there are no approved Federal and/or State hazardous
waste disposal sites in Oklahoma. The Lone Mountain site near Waynoka, Oklahoma
is not in compliance with its permitting requirements. This is not to say that when
remedial action begins at a site there will not be a Federal and/or State approved
disposal facility in the State of Oklahoma.
23. Comment: Is Superfund a congressional appropriation? Does it have a 12 month
limitation on it or is it continuous with an option?
Response: Superfund under SARA is a congressional appropriation which contains
$8.5 billion for a 5 year period. This 5 year period began in 1986.
24. Comment: How much of the $62 million in Superfund monies that has been spent by
EPA Region VI went for actual clean ups as opposed to studies?
Response: Since the program began, over $250 million has been obligated within the
Region VI jurisdiction for Superfund evaluations and cleanups when the commitments
by responsible parties are added to the dollars used from the fund. Of this sum, $200
million is for the design and construction of remedies however this figure cannot be
compared to the remaining $50 million. The Region has found that, in many instances,
responsible parties do not commit to performing site cleanups until EPA's evaluations
are completed and a decision regarding site clean up approach is made. In addition,
about half of the Regions Superfund sites are still under study. For these two reasons
a simple ratio of the amount of monies spent on cleanups versus studies is misleading
and inaccurate.
25. Comment: An adequate health risk assessaent of the existing health risks at the site
and determination of the health risks of the remedial alternatives has not been
conducted.
Response: A qualitative assessment of the potential public health threats in the
absence of remedial action was conducted. This was accomplished in the Compass
Industries Landfill Endangerment Assessment dated July 10, 1987, and amended
August 10, 1987, under the Cooperative Agreement with OSDH.
7
Response: EPA disagrees. Adequate data has been gathered and the evaluations
have been conducted to satisfy the above mentioned guidance documents and
statutory requirements on which to base a decision.
27. Comment: "The Feasibility Study is fundamentally flawed because it fails to consider
lower cost remedial operations that provide protection similar to more expensive
options being considered, contrary to SARA and F.S. guidance requirements."
Response: EPA disagrees with this comment. Numerous alternatives with a wide
range of costs were evaluated in the Feasibilty Study. Most of these alternatives were
eliminated because they could not meet the intent of SARA and the NCP and were not
cost effective. EPA has selected the most cost-effective and technically applicable
alternative.
28. Comment: "The Feasibility Study is fundamentally flawed because it fails to properly
evalute the risk to public health."
Response: EPA disagrees. An endangerment assessment was conducted and
incorporated into the ROD. EPA feels that this endangerment assessment properly
evaluates the risk to public health and adequately supports the proposed remedial
action.
29. Comment: "The Feasibility Study fails to properly analyze and apply applicable or
relevant and appropriate requirements (ARARs)."
Response: EPA disagrees. The applicable or relevant and appropriate requirements
(ARARs) are listed in Table 7-3 of the Feasibility Study. These ARARs were analyzed
and used to evaluate the various alternatives studied.
30. Comment: "Sun was deprived of a reasonable opportunity to participate in the
establishment of an administrative record."
Response: EPA believes that Sun was given sufficient time to evaluate the RI/FS and
to participate in the establishment of an administrative record. In addition, Sun has
been aware of the site activities since at least August 1984. At this time a letter was
sent to Sun requesting information on the site. This letter requested information on
waste generation, transport, and disposal. Public notice of the upcoming comment
period was issued July 22, 1987. Four weeks were allowed for the public comment
period. The comment period began on August 5, 1987, and was orginally scheduled
to close on August 26. An extention to the public comment period changed the closing
date to September 2.
31. Comment: “Failure of the Remedial Investigation to conform to EPA's guidance on
Remedial Investigation under CERCLA procedures for data validity and sufficiency."
Response: EPA disagrees. The Remedial Investigation guidance was adequately
followed and a comprehensive study was conducted.
8
32. Comment: "Quality assurance and quality control measures at the laboratory are not
documented."
Response: EPA disagrees. Quality assurance and quality control procedures were
adequately followed and are documented in a QA/QC plan approved by EPA in April
1984. Actual QA/QC results are included in the Administrative Record.
33. Comment: "Data used in the RI/FS is questionable."
Response: EPA disagrees. Adequate quality data was compiled in which to conduct
a thorough Feasibility Study and to base a remedial action decision. The quality of
this data was assured through the use of a QA/QC plan.
34. Comment: "EPA's basis (air route) for listing this site on the NPL is not borne out by
the RI/FS."
Response: Although air sampling showed minimal respiratory hazard, analysis of
on-site waste justifies need for a response/ remedial action. Analytical results of the
on-site waste is documented in the RI/FS.
35. Comment: "The Remedial Investigation did not conform to the technical workplan
submitted by Mathes on April 25, 1986." (Drilling logs not submitted, etc.)
Response: EPA disagrees. Documentation for the drilling which took place during
the remedial investigation is contained in Appendices A-E of the Remedial
Investigation Report.
36. Comment: "Groundwater data from the lower aquifer is questionable and may have
been introduced by well drilling activity." (This is assumed to refer to old abandoned
petroleum wells existing onsite).
Response: The Remedial Investigation Report indicates that oil well drilling in the
vicinity of the site may have influenced contamination of the lower aquifer. This was
considered in the evaluation of appropriate remedial actions.
37. Comment: "The quantity of samples is insufficient for a meaningful site evaluation."
Response: This is incorrect. An adequate number of samples were collected to
properly evaluate the risks posed by the site and to support the proposed action.
38. Comment: "The Feasibility Study does not address technical feasibility or remedial
options as required by SARA and EPA F.S. Guidance.
9
Response: This is incorrect. The technical feasibility of the remedial options is
covered in section 7.2 of the Feasibility Study. Other references to the technical
feasibility of the alternatives can be found under the title of implementability.
39. Comment: "Cost estimates for remedial alternatives used in the F.S. ar imprecise, do
not reflect likely actual costs of the options and therefore do not allow for meaningful
comparison of costs as required by SARA and EPA's F.S. guidance."
Response: This is incorrect to the extent that the F.S. has adequately evaluated the
cost of the alternatives to enable the selection of the most cost effective alternative.
The intent of the FS cost estimates is to evaluate relative costs and not to give the
level of cost expected in a detailed design report. As indicated in the feasibility study,
the costs for the alternatives are based on cost estimates of -30% to +50%.
40. Comment: "The quality of the background data as reported in the remedial
investigation is admittedly questionable."
Response: EPA disgrees. Due to the random disposal techniques used at the site
and varying hydrogeologic conditions, various contaminant levels were detected at
several different locations. Some background samples do contain higher levels of
some specific compounds compared to other sampling locations. This merely
indicates contamination levels and compounds vary throughout the site.
41. Comment: "The quality of the data reported in the Remedial Investi ation on PCB
contamination is admittedly questionable."
Response: EPA disagrees. The presence of PCBs is documented in two separate
sampling events and is viewed as being reliable data.
42. Comment: “The lack of chain of custody documentation is contrary to EPA's
requirements."
Response: An established chain of custody procedure was followed. This information
is in the Administrative Record.
43. Comment: "The RI and FS fail to analyze and rank compounds present on-site for
potential adverse health effects, as required by EPA RI and FS guidance."
Response: EPA disagrees. Selected indicator compounds, chosen on their potential
for indicating adverse health effects, are indicated in the summary of the
endangerment assessment in the feasibility study.
44. Comment: "Neither the RI nor the FS addresses information gaps that are necessary
to identify and remediate any potential aquifer cross contamination prior to selection
and implementation of the remedy."
10
Response: This information is not considered necessary for implementing the
proposed remedy. Since the only use of the groundwater by the surrounding residents
is upgradient from the site, the need to remediate potential aquifer cross
contamination was not evaluated. (No downgradient groundwater users exists
because the aquifers in question discharge to the surface just north of the site.
45. Comment: "The RI/FS reports fail to follow the format prescribed in EPA guidance."
Response: EPA disagrees. The RI/FS and endangerment assessment follow the
format prescribed in EPA guidance.
11
COMPASS INDUSTRIES
OSDH vs EPA REMEDY COST
COST COMPONENT
OSDH “D” CAP
COST ESTIMATE
EPA “C” CAP
COST ESTIMATE
COST
DIFFERENC
E
Site Development 0 150,000
Fencing 0 47,700
Groundwater Monitoring 0 153,000
Air Monitoring 0 6,500
Cap 3,412,944 4,256,000 843,056
Gas Collection &
Venting
0 36,000
Groundwater Collection
System
0 621,600
Mobilization, Bonds,
Insurance
0 263,540
Health & Safety 0 368,956
Contingency (Bid) 0 790,620
Contingency (Scope) 0 1,054,160
Engineering 341,294 500,000 (A) 158,706
Legal 0 387,404
Construction
Management
273,035 619,846 346,811
Total Capitol &
Implementation
4,027,273 9,255,526
Annual O&M (Includes
Groundwater Treatment)
0 272,830
Total Present Worth 4,027,273 11,827,271 7,799,988
(A) Includes Groundwater Collection & Treatment Design
APPENDIX C
MEMORANDUM
DATE September 15,1987
FROM: Senior Regional Representative
Regional Office for Health Response
ATSDR/ROHRHVI
TO: Paul Sieminiskj
Remedial Project Manager
ALONM Section (6H-SA)
The Agency for Toxic Substance and Disease Registry (ATSDR) has been requested by
the Environmental Protection Agency (EPA) to review and evaluate the Remedial
Investigation/Feasibility Study/Endangerment Assessment data that was generated from
the Compass Industries Superfund Site located in Tulsa, OK.
Currently the ATSDR is reviewing these documents to provide EPA with a comprehensive
Health Assessment for this site.
Based on our review to date, the ATSDR, Regional Office for Health Response in
consultation with staff at ATSDR–Headquarters is of the opinion that the Compass Industry
Superfund Site does pose a current and potential public health threat.
Initial indications are that ATSDR recommendations will be directed toward unacceptable
risks associated with direct public contact and/or unintentional fires at this site.
APPENDIX D
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 10/03/75
Document Type Type Appeal from Decision of City Commission of Tulsa,
Okla.
Originator Troye Kennon
Originator - Affiliation Affiliation Atty. - Compass Industries, Inc.
Recipient Dist. Ct., Tulsa County, Okla.
Recipient - Affiliation
Description Appeal of Tulsa City Commission ruling
Number of Pages 5
Document Number Sequence
Document Date 03/08/76
Document Type Memorandum
Originator Dennis Bergstrom
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Health Dept. Files
Recipient - Affiliation
Description March 5, 1976 inspection of landfill
Number of Pages 1
Document Number Sequence
Document Date Undated, covers inspections from 1/12/76 to 01/19/76
Document Type
Originator Dennis Bergstrom
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Health Dept. Files
Recipient - Affiliation
Description Fires at Chandler Land Fill Jan. 12 through Jan. 19, 1976
Number of Pages 3
Document Number Sequence
Document Date 04/12/76
Document Type Memorandum
Originator Dennis Bergstrom
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Health Dept. Files
Recipient - Affiliation
Description Summary of Inspections 1/12/76 to 4/12/76
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 09/27/76
Document Type Informational Letter
Originator Gary Cox
Originator - Affiliation Public Health Atty. for Tulsa City/Co. Health Dept.
Recipient Doyle and Holmes Law Offices
Recipient - Affiliation Receiver for Compass Industries
Description Informs recipient that Health Dept. seeks their compliance
with state law Re: land fill closure
Number of Pages 1
Document Number Sequence
Document Date 06/15/82
Document Type Summary reports and worksheets
Originator Unknown
Originator - Affiliation
Recipient Unknown
Recipient - Affiliation
Description Computes Hazard Ranking System score
Number of Pages 10
Document Number Sequence
Document Date 09/20/82
Document Type Inspection Report, U.S. E.P.A. Form T2070-3 (10-79)
Originator David Anderson
Originator - Affiliation U.S. E.P.A.
Recipient U.S. E.P.A. Files
Recipient - Affiliation
Description Potential Hazardous Waste Site Inspection Report
Number of Pages 14
Document Number Sequence
Document Date 11/05/82
Document Type Memorandum
Originator Jinks Martin, Jr.
Originator - Affiliation Citizen
Recipient Jerry Cleveland
Recipient - Affiliation Tulsa City/County Health Dept.
Description Complaint about fumes and smoke
Number of Pages 1
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 12/20/82
Document Type General Complaint Form
Originator Martin Bousum
Originator - Affiliation Citizen
Recipient Health Dept. Files
Recipient - Affiliation Tulsa City/Co. Health Dept.
Description Describes problems of Mr. Martin Bousum
Number of Pages 1
Document Number Sequence
Document Date 12/21/82
Document Type Complaint Report
Originator Darrell Roeder
Originator - Affiliation Citizen
Recipient Health Dept. Files
Recipient - Affiliation Tulsa City/Co. Health Dept.
Description Complaints of a Mr. Darrell Roeder
Number of Pages 1
Document Number Sequence
Document Date 01/03/83
Document Type Complaint Report
Originator Martin Bousum
Originator - Affiliation Citizen
Recipient Health Dept. Files
Recipient - Affiliation Tulsa City/Co. Health Dept.
Description Details, complaints of a Mr. Martin Bousum
Number of Pages 1
Document Number Sequence
Document Date 01/03/83
Document Type Complaint Report
Originator Thorunn M. Gilstrap
Originator - Affiliation Citizen
Recipient Heal Dept. Files
Originator - Affiliation Tulsa City/Co. Health Dept.
Description Complaints of Mr. Thorunn M. Gilstrap
Number of Pages 1
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 01/14/83
Document Type Letter
Originator Mark S. Coleman
Originator - Affiliation State Dept. of Health
Recipient Dr. Edgar Cleaver
Recipient - Affiliation Tulsa City/County Health Dept. (TCCHD)
Description TCCDH as plaintiff in any action brought by Tulsa Co.
Dist. Atty.
Number of Pages 1
Document Number Sequence
Document Date 01/17/83
Document Type Resolution
Originator Terry Young
Originator - Affiliation Tulsa County Board of County Commissioners
Recipient
Recipient - Affiliation
Description Requests Dist. Atty. To initiate action abating the public
nuisance at Tulsa Refuse Dump No. 1
Number of Pages 1
Document Number Sequence
Document Date 01/28/83
Document Type Petition filed in Tulsa County Dist. Ct.
Originator Tulsa County Board of County Commissioners, Tulsa
City/County Health Dept., State of Okla.
Originator - Affiliation
Recipient Filed in Tulsa County Dist. Ct.
Recipient - Affiliation
Description Requests the court hold hearings on alleged violations
Number of Pages 8
Document Number Sequence
Document Date 03/28/83
Document Type Memorandum
Originator Gary S. McDonald
Originator - Affiliation Solid Waste Division, Okla. State Dept. of Health
Recipient Health Dept . Files
Recipient - Affiliation
Description Describes sampling conducted 3/23/83
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 03/28/83
Document Type Memorandum
Originator Joseph Dunagan
Originator - Affiliation Industrial Waste Division, Okla. State Dept. of Health
(OSDH)
Recipient Richard Thompson
Recipient - Affiliation Solid Waste Division (OSDH)
Description Reconnaissance of land fill prior to 3/28/83
Number of Pages 2
Document Number Sequence
Document Date 03/28/83
Document Type Air quality evaluation of land fill fire
Originator Air Quality Staff, Tulsa City/County Health Dept.
Originator - Affiliation TCCHD
Recipient Health Dept. Files
Recipient - Affiliation
Description Summarizes monitoring activities from 10/26/82 to 1/28/83
Number of Pages 28
Document Number Sequence
Document Date 04/26/83
Document Type Press Release
Originator Eddie Lee
Originator - Affiliation U.S. E.P.A.
Recipient
Recipient - Affiliation
Description Press release stating U.S. E.P.A. will conduct further air
quality tests
Number of Pages 1
Document Number Sequence
Document Date 06/09/83
Document Type Record
Originator Cynthia Bachunas
Originator - Affiliation Unknown
Recipient Russell Bartley (U.S. E.P.A.) and Ken Raymond (Okla.
State Dept. Health)
Recipient - Affiliation
Description Hazard Ranking System
Number of Pages 29
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 06/10/83
Document Type Section 3007 Request for Information
Originator Dick Whittington
Originator - Affiliation U.S. E.P.A.
Recipient Bill Jackson
Recipient - Affiliation Owner of Compass Industries landfill
Description Possible receipt of hazardous waste
Number of Pages 3
Document Number Sequence
Document Date 09/02/83
Document Type 3007 Request for Information
Originator Allyn M. Davis
Originator - Affiliation U.S. E.P.A.
Recipient John Deatherage
Recipient - Affiliation Standard Industries
Description Wastes received at Compass and on Standard Industries’
purchase of site
Number of Pages 3
Document number Sequence
Document Date 01/10/84
Document Type Letter
Originator Russell Bartley
Originator - Affiliation U.S. E.P.A.
Recipient Fenton Rood
Recipient - Affiliation Okla. State Dept. of Health
Description Compass Industries Workplan
Number of Pages 3
Document Number Sequence
Document Date 03/01/84
Document Type Quality Assurance Project Plan
Originator Okla. State Dpt. Of Health
Originator - Affiliation
Recipient Health Dept. Files
Recipient - Affiliation
Description Quality Assurance project Plan
Number of Pages 114
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 04/18/84
Document Type Memorandum
Originator Paul Sieminski, Project Officer
Originator - Affiliation U.S. E.P.A. Region (6AW-SP)
Recipient Ray Lozano, Coordinator
Recipient - Affiliation Office of Quality Assurance
Description QAPP-Compass Cooperative Agreement
Number of Pages 3
Document Number Sequence
Document Date 05/07/84
Document Type Letter
Originator Paul Sieminski
Originator - Affiliation U.S. E.P.A.
Recipient Fenton Rood
Recipient - Affiliation Okla. State Dept. of Health
Description Approval of 3/1/84 version of Quality Assurance Project
Plan
Number of Pages 1
Document Number Sequence
Document Date 06/15/84
Document Type Health and Safety Plan
Originator David Wharton
Originator - Affiliation Okla. State Dept. of Health
Recipient Health Dept. files
Recipient - Affiliation
Description Health and Safety Plan for remedial Investigation
Number of Pages 7
Document Number Sequence
Document Date 08/20/84
Document Type Minutes of Public Meeting
Originator Okla. State Dept. of Health
Originator - Affiliation
Recipient Health Dept. Files
Recipient - Affiliation
Description Minutes of public meeting held 8/20/84
Number of Pages 3
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 11/28/84
Document Type Letter
Originator John R. Totin
Originator - Affiliation Ecology and Environment, Inc.
Recipient Ken Burns
Recipient - Affiliation Okla. State Dept. of Health
Description Describes monitoring well installation and sampling
Number of Pages 14
Document Number Sequence
Document Date 01/11/85
Document Type Letter of response
Originator Dick Whittington, Regional Administrator Region VI
Originator - Affiliation U.S. E.P.A.
Recipient I.J. Ramsbottom, Environmental Clearance Officer
Recipient - Affiliation Dept. Housing & Urban Development
Description HUD’s Draft Environmental impact Statement
Num er of Pages 4
Document Number Sequence
Document Date 01/23/85
Document Type Letter
Originator Mike Wright/Solid & Industrial Waste
Originator - Affiliation Tulsa City/County Health Dept.
Recipient Ken Burns - Superfund Projects
Recipient - Affiliation Okla. State Dept. of Health
Description Steps to contact access to landfill
Number of Pages 2
Document Number Sequence
Document Date 02/00/85
Document Type Preliminary Report
Originator Okla. State Dept. of Health
Originator - Affiliation State agency
Recipient For Okla. State Dept. of Health files
Recipient - Affiliation State agency
Description Preliminary Report - Compass Industries
Number of Pages 9
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 03/85
Document Type Magazine articles, editor’s pg., table of contents
Originator Maria Weldings, Patsy Varnell
Originator - Affiliation Berryhill Citizens for Safe Environment
Recipient Oklahoma Sierran
Recipient - Affiliation Sierra Club/Okla. Chp.
Description Historical overview of Compass Landfill
Number of Pages 3-4/4
Document Number Sequence
Document Date 04/03/85
Document Type Newspaper article
Originator Julie DelCour
Originator - Affiliation Tulsa World Newspaper - Staff
Recipient Public
Recipient - Affiliation
Description Dismissal of $150 million Lawsuit
Number of Pages 1
Document Number Sequence
Document Date 04/22/85
Document Type Letter
Originator Ken Burns - Superfund Project Coordinator
Originator - Affiliation Okla. State Dept. of Health
Recipient Thomas J. DiRito
Recipient - Affiliation Bellaman Community Development
Description Shenandoah Project - amid Springs, Okla.
Number of Pages 2
Document Number Sequence
Document Date 06/12/85
Document Type Sampling Plan
Originator Okla. State Dept. of Health
Originator - Affiliation State agency
Recipient For Dept. of Health files (Okla.)
Recipient - Affiliation State Agency
Description Groundwater monitoring sampling plan
Number of Pages 13
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 10/00/85
Document Type Planning - Study Reports
Originator Okla. State Dept. of Health Waste Mgmt. Service
Originator - Affiliation
Recipient For Dept. of Health files (Okla.)
Recipient - Affiliation State agency (Okla.)
Description Health and Safety Plan - RI
Number of Pages 33
Document Number Sequence
Document Date Undated apparently March 1986
Document Type Trenching Sampling Plan
Originator Okla. State Dept. of Health
Originator - Affiliation
Recipient Health Dept. Files
Recipient - Affiliation
Description Plan for trenching and sampling
Number of Pages 9
Document Number Sequence
Document Date 04/28/86
Document Type Technical Work Plan
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation
Description Plan Re: exploration services for RI
Number of Pages 27
Document Number Sequence
Document Date 05/01/86
Document Type News release
Originator Okla. State Dept. of Health
Originator - Affiliation State agency
Recipient Public
Recipient - Affiliation
Description Historical background Re: Compass landfill
Number of Pages
Document Number Sequence 2
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 05/13/86 - 05/31/86
Document Type Record
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation
Description Daily driller’s record
Number of Pages 13
Document Number Sequence
Document Date 05/16/86
Document Type Letter of Review
Originator Douglas Kent
Originator - Affiliation MDK Consultants
Recipient Thomas DiRito
Recipient - Affiliation Bellamah Community Development
Description Review of proposed monitoring plan
Number of Pages 14
Document Number Sequence
Document Date 05/28/86
Document Type Letter
Originator Thomas J. DiRito - Tulsa Mgr.
Originator - Affiliation Bellamah Community Development
Recipient Hal Cantwell - Environmental Specialist
Recipient - Affiliation Okla. State Dept. of Health
Description Review of proposed monitoring plan
Number of Pages 1
Document Number Sequence
Document Date Undated
Document Type Report
Originator Unknown - probably U.S. E.P.A. (6)
Originator - Affiliation U.S. E.P.A. Region VI
Recipient U.S. E.P.A. Region VI - Compass File
Recipient - Affiliation
Description General overview of site
Number of Pages 13
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 14/01/87
Document Type Letter
Originator Allyn M. Davis, Director
Originator - Affiliation Hazardous Waste Mgtment Service/U.S. E.P.A.
Recipient Mark Coleman, Deputy Commissioner
Recipient - Affiliation Okla. State Dept. of Health
Description Correspondence Re: RI/FS
Number of Pages 1
Document Number Sequence
Document Date 04/03/87
Document Type Letter; sampling plan
Originator Hal Cantwell, ES
Originator - Affiliation Superfund Program/Solid Waste Division, Okla. State
Dept. of Health
Recipient Paul Sieminski (6H-SS)
Recipient - Affiliation U.S. E.P.A.
Description Industries Dioxin Testing
Number of Page 6
Document Number Sequence
Document Date 04/15/87
Document Type Memorandum
Originator R. Fenton, Rood, Director
Originator - Affiliation Solid Waste Division
Recipient Mark Coleman, Deputy Commissioner
Recipient - Affiliation Environmental Health Services
Description March Progress Report
Number of Pages 3
Document Number Sequences
Document Date 05/13/87
Document Type Cover letter, Action Specific Requirements
Originator Hal Cantwell/Environmental Specialist
Originator - Affiliation U. S. E. P. A.
Recipient Carl Edlund, Chief
Recipient - Affiliation U. S. E. P. A.
Description Action-specific State of Okla. ARARs
Number of Pages 5
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 05/21/87
Document Type Cover letter, Analytical Results
Originator Dale Markley, Sr., Hydrogeologist
Originator - Affiliation Jn. Mathes & Assoc., Inc.
Recipient Hal Cantwell
Recipient - Affiliation Okla. State Dept. of Health
Description Analytical Results - Dioxin & Furans/RI/FS
Number of Pages 19
Document Number Sequence
Document Date 07/10/87
Document Type Assessment
Originator Dr. Raymond Harlison - Dept. Medical Science
Originator - Affiliation Univ. of Ark.
Recipient Jn. Mathes & Assoc., Inc.
Recipient - Affiliation
Description Endangerment Assessment
Number of Pages 111
Document Number Sequence
Document Date 07/13/87
Document Type Report by engineering firm for Compass
Originator John Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State agency
Description RI Report for Compass Industries/Vol. I
Number of Pages 156 - 2 pgs. “References”
Document Number Sequence
Document Date 07/13/87
Document Type Appendix -R/I Report/Compass Industries (A-E)
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State agency
Description Appendix for Engineering logs Vol II
Number of Pages 99
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 07/13/87
Document Type Appendix R/I Report/Compass Industries (F)
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State Agency
Description Appendix for Analytical Data Vol III
Number of Pages 223
Document Number Sequence
Document Date 07/13/87
Document Type Appendix - P/I Report (F continued)
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation Engineering firm
Recipient Okla. State Dept. of Health
Recipient - Affiliation State Agency
Description Appendix for Analytical Data Vol. IV
Number of Pages 228
Document Number Sequence
Document Date 07/13/87
Document Type Report
Originator John Mathes & Assoc., Inc.
Originator - Affiliation
Recipient Ok. State Dept. Health
Recipient - Affiliation
Description Feasibility Study Report
Number of Pages 121
Document Number Sequence
Document Date 08/10/87
Document Type Assessment
Originator John Mathes & Assoc., Inc.
Originator - Affiliation
Recipient Ok. State Dept. Health
Recipient - Affiliation
Description Endangerment Assessment
Number of Pages 116
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 8/10/87
Document Type Addendum
Originator Jn. Mathes & Assoc., Inc.
Originator - Affiliation
Recipient OK State Dept. Health
Recipient - Affiliation
Description Addendum - Endangerment Assess. Exhibits A-F
Number of Pages 140
Document Number Sequence
Document Date 08/18/87
Document Type Letter
Originator Jerry Cleveland, Asst. Director
Originator - Affiliation Tulsa City/Co. Health Dept.
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Response to Health Dept.’s recommend.
Number of Pages 1
Document Number Sequence
Document Date 08/18/87
Document Type Memorandum
Originator Betty Jean Reece, Project Officer
Originator - Affiliation U.S. E.P.A. (6) 6H-SS
Recipient U.S. E.P.A. (6) Compass File
Recipient - Affiliation
Description Meeting 08/18/87
Number of Pages 2
Document Number Sequence
Document Date 08/20/87
Document Type Letter
Originator Wm. R. Cox - Dir. Utility Plants/Opera.
Originator - Affiliation City of Sand Springs
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Comments Re: Compass Site
Number of Pages 3
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 08/21/87
Document Type Letter
Originator David Page - Atty.
Originator - Affiliation Boone, Smith, Davis & Hurst - Law Office
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Extension of public comment period
Number of Pages 1
Document Number Sequence
Document Date 08/25/87
Document Type Letter
Originator Hal D. Cantwell, Environ. Special.
Originator - Affiliation OK State Dept. Health
Recipient Carl Edlund, Chief (6H-S)
Recipient - Affiliation SuperFund Program - U.S. E.P.A. (6)
Description Extension - Public Comment Period
Number of Pages 1
Document Number Sequence
Document Date 08/27/87
Document Type Letter
Originator R. Fenton Rood, Dir.
Originator - Affiliation OK State Dept. Health
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Public comments Re: selection of remedy
Number of Pages 5
Document Number Sequence
Document Date 08/27/87
Document Type Letter
Originator Evelyn Reid
Originator - Affiliation Citizen - Tulsa, OK
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Program
Description Response to public meeting
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 08/28/87
Document Type Letter
Originator Shawn Thorton
Originator - Affiliation Citizen - Bartlesvilles, OK
Recipient Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Program
Description Response to public meeting
Number of Pages 1
Document Number Sequence
Document Date 08/31/87
Document Type Letter
Originator John Selph
Originator - Affiliation Board of Co. Commissioners
Recipient Carl Edlund, Chief
recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description State Health Dept.’s proposed remedy
Number of Pages 2
Document Number Sequence
Document Date 08/31/87
Document Type Letter
Originator Mark Coleman, Deputy Commissioner
Originator - Affiliation OK Dept. of Health
Recipient Robt. Layton, Reg. Admin.
Recipient - Affiliation U.S. E.P.A. Region VI
Description RA alternatives
Number of Pages 1
Document Number Sequence
Document Date 09/01/87
Document Type Letter/attach.
Originator R. Fenton Rood, Director
Originator - Affiliation OK State Dept. Health
Recipient Carl Edlund Chief (6H-S)
Recipient - Affiliation U.S. E.P.A. Region VI
Description Public comments/summary table
Number of Pages 2
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 09/01/87
Document Type Letter
Originator Charles W. Shipley - Atty.
Originator - Affiliation Law Firm - Shipley & Schneider
Recipient Carl Edlunds, Chief
Recipient - Affiliation U.S. E.P.A. (6) SuperFund Programs
Description Response to ROD
Number of Pages 3
Document Number Sequence
Document Date 09/02/87
Document Type Letter/attachment
Originator Edward A. Kurent - Atty.
Originator - Affiliation Pepper, Hamilton & Scheetz - Law firm
Recipient, Carl Edlund, Chief
Recipient - Affiliation U.S. E.P.A. (Region VI - 6H-S)
Description Comments on RI/FS Reports
Number of Pages 41
Document Number Sequence
Document Date 09/10/87
Document Type Letter
Originator Jerry Lasker, Exec. Director
Originator - Affiliation Indian Nations Council of Govts.
Recipient Robt. Layton - Regional Admin.
Recipient - Affiliation U.S. E.P.A. Region VI
Description Comments Re: ROD
Number of Pages 3
Document Number Sequence
Document Date 09/28/87
Document Type Letter/attachment
Originator Edward A. Kurent - Atty.
Originator-Affiliation Law firm - Petter, Hamilton & Scheetz
Recipient Carl Edlund/Julie Bozich
Recipient - Affiliation U.S. E.P.A. Region VI
Description Comments Re: RI/FS; unindexed AR docu.
Number of Pages 73
Document Number Sequence
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number: 0983
Document Date 09/29/87
Document Type Letter
Originator Mark S. Coleman, Depty. Commiss.
Originator - Affiliation OK State Dept. of Health
Recipient Allyn Davis, Director
Recipient - Affiliation U.S. E.P.A. Region VI
Description Acceptance of ROD
Number of Pages 1
Document Number Sequence
APPENDIX E
September 29, 1987
Allyn M. Davis, Director
Hazardous Waste Management Division
Environmental Protection Agency
Region VI
Dallas, Texas 73202-2733
Dear Dr. Davis:
The Oklahoma State Department of Health (OSDH) has reviewed the Declaration for the
Record of Decision for the Compass Industries site Tulsa, Oklahoma. The OSDH does
concur with the selected remedy detailed in the Declaration. The OSDH looks foward to
continuing to work together with the EPA towards a solution to the problems at the
Compass Industries site.